Court of Appeal of Tanzania

This is the highest level in the justice delivery system in Tanzania. The Court of Appeal draws its mandate from Article 117(1) of the Constitution of the United Republic of Tanzania. The Court hears appeals  on both point of law and facts for cases originating from the High Court of Tanzania and Magistrates with extended jurisdiction in exercise of their original jurisdiction or appellate and revisional jurisdiction over matters originating in the District Land and Housing Tribunals, District Courts and Courts of Resident Magistrate. The Court also hears similar appeals  from quasi judicial bodies of status equivalent to that of the High Court. It  further hears appeals  on point of law against the decision of the High Court in  matters originating from Primary Courts. The Court of Appeal also exercises jurisdiction on appeals originating from the High Court of Zanzibar except for constitutional issues arising from the interpretation of the Constitution of Zanzibar and matters arising from the Kadhi Court.

Physical address
26 Kivukoni Road Building P.O. Box 9004, Dar Es Salaam, Tanzania.
28 judgments

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28 judgments
Citation
Judgment date
November 2022
Conviction quashed where medical exhibit was irregularly admitted and evidence, lacking key witnesses, proved only suspicion.
Criminal law – rape of a child – competency and non-production of child witness; admissibility of medical report (PF3) requiring reading/explanation after admission; sufficiency of circumstantial and hearsay evidence; duty to call material witnesses (street chairperson).
9 November 2022
Child’s unpromised testimony must be expunged, but being caught in flagrante delicto can sustain conviction.
Evidence – Child witness (section 127(2) Evidence Act) – failure to promise to tell truth requires expungement; Voir dire – absence of record; Identification – caught in flagrante delicto removes identification doubt; Medical evidence (PF3/Exh PEI) corroborates penetration; Sufficiency of remaining evidence to sustain conviction.
9 November 2022
Failure by a first appellate court to decide all substantial grounds is fatal; matter remitted for rehearing.
* Criminal procedure – first appeal – duty of first appellate court to re-appraise evidence and determine grounds of appeal – necessity to give reasons or indicate combination of grounds; failure is fatal and warrants quashing and remittal for rehearing.
9 November 2022
Failure to properly inform and direct assessors, especially on provocation, vitiated the murder trial; retrial ordered.
Criminal procedure – murder trial with assessors – duty to inform assessors of their role and responsibilities before trial – duty to sum up and explain relevant law and defences (including provocation) – non-direction or misdirection on vital point renders trial a nullity – retrial ordered.
7 November 2022
Omission of court name on charge sheet is curable; an unequivocal guilty plea bars challenge to conviction.
* Criminal procedure – charge sheet contents – omission of trial court’s name – curable defect where essential particulars disclosed (s.132 CPA). * Plea of guilty – when plea is unequivocal – admission of facts and mitigation confirm plea – limits on appeals from guilty pleas. * Evidence – no requirement to tender exhibits once accused pleads guilty and admits facts disclosing all elements of offence.
7 November 2022
Failure by the High Court to decide all grounds of appeal rendered its judgment null, warranting remittal for rehearing.
Criminal appeal — First appellate court’s duty to address grounds of appeal — Failure to determine all grounds is a fatal irregularity — Nullity of proceedings — Remittal for rehearing before a different judge; limited circumstances where higher court may re-evaluate evidence to avoid delay.
7 November 2022
Trial was a nullity for failing to inform assessors and explain vital legal points; retrial ordered.
* Criminal procedure – Trials with assessors – Duty to inform assessors of their role and responsibilities – Necessity of meaningful participation. * Criminal procedure – Summing up under section 298(1) – Requirement to explain vital points of law to assessors before inviting opinions (confession, provocation). * Non-compliance with sections 265 and 298(1) – Fatal omission rendering trial a nullity – Retrial as appropriate remedy.
7 November 2022
Failure to address and properly sum up to assessors vitiated the trial; conviction quashed and retrial ordered.
Criminal procedure — Trials with assessors — mandatory requirement to address assessors on their role and responsibilities; requirement to sum up substance of evidence and vital points of law (dying declarations, confessional statements, defences) to assessors; failure to do so vitiates proceedings; retrial ordered where evidence is not hopelessly weak.
7 November 2022
Conviction quashed where contradictions and unlawful corroborative evidence undermined proof beyond reasonable doubt.
Criminal law – sexual offences against a child – credibility of child witness under section 127 Evidence Act; cautioned statement – statutory time limits under section 50 CPA – inadmissibility if exceeded; PF3 medical report – reliability and requirement to record referral/date; contradictions in prosecution evidence going to the root – acquittal.
4 November 2022
Inadequate summing up to assessors vitiated the trial; convictions quashed and retrial ordered.
* Criminal procedure – Assessors – Summing up to assessors – Requirement to summarise substance of prosecution and defence and explain vital legal points (s.298(1) CPA) – Failure to properly sum up vitiates proceedings. * Trial irregularity – Inadequate summing up renders assessors' opinions unreliable and may nullify conviction. * Remedy – Convictions quashed, sentences set aside and retrial ordered with assessors per s.265(1) CPA. * Evidential issues (retracted cautioned statement) raised but not determined due to procedural nullity.
4 November 2022
Failure to properly sum up to assessors renders the trial a nullity and warrants an expedited retrial.
Criminal procedure — Summing up to assessors — Requirement under section 298(1) CPA to summarise facts and explain relevant law — Failure to do so renders trial a nullity; retrial ordered. — Assessors’ role — Section 265(1) CPA. — Cautioned statement (admission) issue not determinative in view of fatal summing-up omission.
4 November 2022
Inadequate summing-up to assessors rendered the trial a nullity; conviction quashed and retrial ordered.
* Criminal procedure – Summing-up to assessors – Section 298(1) CPA – duty to explain substance of evidence and vital legal points; failure is fatal. * Assessors – inability to give meaningful opinion where summing-up is inadequate – renders trial without aid of assessors and nullity. * Confessional statement – retracted cautioned statement – evidential value and need for proper directions in summing-up. * Remedy – conviction quashed and sentence set aside; retrial (trial de novo) ordered before another Judge with assessors (s265(1)).
3 November 2022
Where an accused's age is disputed the court must inquire under the Law of the Child Act; failure warrants quashing and retrial.
Criminal procedure — disputed age of accused — duty to inquire under Law of the Child Act ss.113–114 and Rule 12 (Juvenile Court Procedure Rules) — proof by birth certificate, medical evidence, school records or social welfare information — failure to inquire constitutes miscarriage of justice; remedy: quash conviction and order retrial.
1 November 2022
October 2022
Inadequate summing up to assessors on circumstantial evidence and confession renders the trial a nullity; retrial ordered.
* Criminal procedure – summing up to assessors – section 298(1) CPA – mandatory duty to explain substance of evidence and direct on salient legal points; * Evidence – circumstantial evidence and presumption of last person seen with deceased – requirement to direct assessors; * Evidence – confessional/cautioned statement – need to direct on reliability; * Procedural irregularity – inadequate summing up renders trial without assessors and a nullity; * Remedy – conviction quashed, sentence set aside, retrial ordered.
31 October 2022
Failure to inform and properly address assessors vitiated the trial; conviction quashed and retrial ordered.
Assessors' participation – must be informed of roles before trial; summing up to assessors – judge must summarize evidence and explain vital points of law (circumstantial evidence, corroboration, retracted confession, common intention, last-seen doctrine); introduction of extraneous matters in summing up vitiates trial; where trial vitiated by such defects, retrial may be ordered.
31 October 2022
Material variance between charged date and prosecution evidence undermined proof beyond reasonable doubt; conviction quashed.
Criminal law – unnatural offence – variance between charge particulars (date) and prosecution evidence – duty of prosecution to prove particulars – requirement to amend charge under section 234(1) Criminal Procedure Act – failure to address variance amounts to fatal defect.
28 October 2022
May 2022
Demolition lawful where applicant developed in a declared planning area without permit and failed to comply with enforcement notices.
Urban planning and development law — planning area designation; requirement of planning consent/building permit fordevelopment; enforcement notices and demolition for non-compliance; retrospective inapplicability argument rejected whereprior planning regime applied; water-source protection considerations.
2 May 2022
March 2022
Whether a handwritten disposition and competing land titles were valid and whether both certificates should be set aside.
* Land law – disposition of registered land – validity of handwritten donation and requirement of corroborative evidence. * Evidence – burden of proof on party alleging disposition; elevated standard to prove fraud in civil proceedings. * Titles – competing certificates of occupancy/title; court’s power to declare titles invalid where earlier title exists or process tainted. * Probate/administration – appointment as administratrix does not automatically confer ownership of estate land.
31 March 2022
Court of Appeal dismissed review: it may only review its own judgment, not re-open lower court proceedings.
Review — Scope of review under s.4(4) AJA and rule 66(1) Court of Appeal Rules — review confined to this Court's judgment or order; error on face of the record means this Court's record. Jurisdiction — may be raised anytime but in review must be apparent on the Court of Appeal's record. Amendments to plaint and new evidence in subordinate courts — matters for High Court review (Order XLII CPC), not for Court of Appeal review.
31 March 2022
Conviction upheld: cautioned statements expunged; admission and corroboration sustain warrantless-search evidence.
Criminal law – possession of government trophies – admissibility of cautioned statements recorded outside statutory four-hour limit – expunged. Criminal procedure – change of trial magistrate – compliance with s.214(1) CPA and prejudice test. Criminal procedure – warrantless search of premises – non-fatal where accused admits possession and was present during search. Evidence – co-accused admission admissible against another (Evidence Act s.33) when corroborated. Evidence – competence of game ranger/wildlife ranger to value trophies under Wildlife Conservation Act s.86(4).
30 March 2022
Failure to administer and record oath to CMA witnesses vitiates proceedings; award and High Court order quashed and remitted for rehearing.
Labour law – CMA procedure – Rule 19(2)(a) and Rule 25(1) – witnesses must testify on oath or affirmation – failure to record oath/affirmation vitiates proceedings – record must show compliance – indication in award does not cure defect – remedy: quash and remit for rehearing before different arbitrator.
28 March 2022
Conviction quashed where alleged trophy exhibits were admitted for identification only and not produced in evidence.
Criminal law – evidence – identification-only exhibits have no evidential value; inventories substitute only for perishable exhibits with proper disposal orders – non-production of core physical exhibits undermines proof beyond reasonable doubt.
25 March 2022
Victim and corroborative evidence upheld conviction; thirty‑year sentence quashed and substituted with mandatory life imprisonment.
* Criminal law – Unnatural offence – Evidence – Victim’s direct testimony corroborated by eyewitness and medical oral evidence establishing penetration – PF3 expunged but oral testimony survives. * Procedural – Delay in arrest immaterial where offence was reported promptly. * Sentencing – Section 154(2) Penal Code (as amended) mandates life imprisonment for unnatural offences against persons under 18; appellate court may substitute illegal sentence under s.4(2) AJA.
25 March 2022
Failure to inform assessors of their role and to properly sum up legal issues vitiated the trial, requiring quashing of conviction and retrial.
* Criminal procedure – Trials with aid of assessors – Requirement to inform assessors of their role and responsibilities – failure renders trial not with aid of assessors and is fatal. * Criminal procedure – Summing up – Necessity to explain salient facts in relation to law (e.g., identification and circumstantial evidence) to assessors for meaningful opinions. * Appeal – Procedural irregularity – Inadequate involvement of assessors vitiates conviction and warrants retrial.
24 March 2022
Improper voir dire rendered the child-victim incompetent; conviction quashed for lack of admissible corroboration.
Criminal law – Child witness competence – Section 127(2) Evidence Act – Proper voir dire required to establish understanding of oath and duty to tell truth; unsworn/incompetent child evidence has no value; PF3 inadmissible without authoring medical witness or readout; accused cannot be convicted on weakness of defence.
24 March 2022
Convictions quashed because visual identification evidence was unreliable and identification parade added no value.
* Criminal law – Visual identification – sufficiency and reliability of eye-witness identification; contradictions and signs of tutoring undermine conviction. * Criminal procedure – Identification parade – limited value where witnesses were familiar with suspect. * Evidence – failure to name suspect at earliest opportunity affects reliability. * Charging – caution against separate counts for assault/grievous harm where they form ingredients of armed robbery.
24 March 2022
Identification by recognition and voice in poor lighting was unreliable to convict the applicants.
* Criminal law – Evidence – visual identification by recognition – Courts must eliminate all possibilities of mistaken identity before acting on single-witness identification. * Criminal law – Evidence – identification at night – source and intensity of light must be explained. * Criminal law – Evidence – voice identification – inherently weak and requires careful scrutiny (strength, duration, familiarity). * Criminal procedure – Appellate review – convictions unsafe where identification evidence is unreliable.
24 March 2022
Uncontradicted affidavit and excusable delay justified extension of time to apply to set aside an ex parte judgment.
Civil procedure — Extension of time — Good cause — Applicant's uncontradicted affidavit sufficient to prove date of knowledge — Ex parte judgment — Accounting for delay — Technical/clerical defects in earlier applications do not necessarily indicate applicant's negligence.
22 March 2022