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.

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26 Kivukoni Road Building P.O. Box 9004, Dar Es Salaam, Tanzania.
47 judgments

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47 judgments
Citation
Judgment date
December 2022
Appellant's rape conviction quashed where prosecution failed to prove penetration and positive identification.
Criminal law – rape – requirement to prove penetration and lack of consent beyond reasonable doubt; identification by recognition – reliability and contradictions; evidence of witness of tender years – compliance with s.127(2) Evidence Act; duty to call material witnesses and adverse inference; appellate review where lower courts misapprehend evidence.
8 December 2022
Inadequate summing up and improperly relied cautioned statements rendered the trial a nullity; convictions quashed and sentences set aside.
Criminal appeal – inadequate summing up to assessors – summing up omissions (malice, actus reus, confessions) – cautioned statements not admitted at main trial cannot be relied upon – certificate of seizure/mobile phone evidence expunged – trial without proper assessors’ participation is nullity – retrial not ordered where remaining evidence is weak.
8 December 2022
Conviction for rape of an eight‑year‑old upheld where age, penetration and victim's account were credibly proved.
Criminal law – Rape of a child – Proof of age and penetration – PF3 and birth certificate corroboration; delay in reporting – threats and inducements as plausible explanation; defence of impotence – credibility and lack of corroboration; concurrent findings – appellate interference.
7 December 2022
First appellate court’s failure to analyse defence evidence did not prevent Court of Appeal affirming the appellant's convictions.
* Criminal law – appellate review – duty of first appellate court to re-evaluate and analyse both prosecution and defence evidence; * Appellate Jurisdiction Act s.4(2) – Court of Appeal stepping into the shoes of first appellate court; * Offences – fraudulent appropriation of power, malicious damage to property, personation of public officer, obtaining money by false pretence; * Evidence – sufficiency and corroboration; unexplained proceeds as evidence of fraud.
7 December 2022
A voluntary confession plus parental and medical evidence can establish rape despite improperly recorded child testimony.
* Evidence – Cautioned/confession statements – admissibility – objection must be raised at trial; failure to object precludes complaint on appeal. * Evidence – No requirement to repeat police‑recorded cautioned statement in court where voluntariness not challenged. * Evidence – Proof of child’s age – parental testimony and medical evidence admissible. * Evidence – Child witness – section 127(2) Evidence Act non‑compliance invalidates testimony. * Criminal law – Confession corroborated by medical evidence of penetration can prove rape beyond reasonable doubt.
7 December 2022
Inadequate summing up to assessors that omits vital legal directions warrants nullification and retrial.
Criminal procedure – assessors: duty to be informed of role; summing up: must explain vital points of law (ingredients of offence, burden of proof, malice aforethought, identification, cautioned statements, defences, absence of postmortem); inadequate summing up amounts to miscarriage of justice – remedy: nullify proceedings, quash conviction and order retrial.
7 December 2022
Concurrent findings of credibility, medical evidence and unobjected cautioned statement upheld conviction for rape of a nine-year-old.
Criminal law – Rape of a child – Proof of age and penetration; cautioned statements – admissibility requires timely objection at trial; second appeal – deference to concurrent findings of credibility; relevance of victim's school class in rape of a child.
7 December 2022
November 2022
Conviction quashed where victim’s inconsistent account and failure to consider defence evidence raised reasonable doubt.
Criminal law – Rape – elements: age and penetration – victim's testimony as best evidence but must be scrutinised; Medical evidence (PF3) corroboration; Credibility assessment – inconsistent accounts, delayed complaint and failure to name suspect at earliest opportunity; Appellate review – interference with concurrent findings where there is misapprehension of evidence or failure to consider defence; Duty of trial and first appellate courts to evaluate and weigh defence evidence.
7 November 2022
October 2022
Committal notice failure and inadequate guidance to assessors rendered trial evidence inadmissible and convictions unsustainable.
Criminal procedure – committal proceedings and notice – section 289(1) CPA; inadmissibility and expunction of witnesses/exhibits not listed at committal.\nCriminal procedure – role of assessors – judge’s duty to adequately sum up on vital legal points (visual identification, circumstantial evidence, recent possession, confessional statements) – misdirection vitiates proceedings.\nEvidence – visual identification and identification parade reliability.\nRemedy – quashing convictions and sentences; discretionary refusal to order retrial.
19 October 2022
Second-bite leave in land appeals is competent after s.47 amendment; arguable illegality granted leave to appeal.
* Appeal – Land law – Second-bite leave under Rule 45(b) – Competence after 2018 amendment of s.47 Cap.216 – High Court and Court of Appeal concurrent jurisdiction; * Judicial procedure – Leave to appeal – Prima facie illegality – Failure to record assessors’ opinions; unexplained change of assessors; jurisdictional challenge; alleged double allocation; * Relief – Leave to appeal granted; no order as to costs.
19 October 2022
Assessors' briefing omission cured; despite some errors expunged, evidence sufficed to uphold murder conviction and death sentence.
Criminal appeal — assessors' briefing omission cured where assessors actively participated; admissibility — error in court referring to non‑tendered cautioned statement must be expunged; discrepancies in delayed witness testimony may be minor; last‑seen doctrine and eyewitness/autopsy evidence can sustain murder conviction; rejection of defence does not imply non‑consideration.
18 October 2022
Trial by a magistrate lacking a High Court transfer order is a jurisdictional nullity and cannot be cured by overriding objective.
* Criminal procedure – Transfer under s.256A(1) CPA – transfer must be directed to a specific resident magistrate with extended jurisdiction. * Jurisdiction – Proceedings, trial and judgment by magistrate lacking a transfer order are a nullity. * Overriding objective / s.388 CPA – cannot cure jurisdictional defects. * Appellate revision – s.4(2) AJA used to nullify proceedings, quash conviction and remit record to High Court.
18 October 2022
Trial conducted outside the territorial court specified in the transfer order lacked jurisdiction and was nullified.
Criminal procedure – Transfer under section 256A(1) CPA – Territorial jurisdiction – Resident Magistrate with extended jurisdiction must sit at court and region specified by transfer order – Trial held outside designated territorial court is nullity – Proceedings quashed and remitted to High Court.
13 October 2022
Extension of time under rule 10 is discretionary and not time-barred; application struck out after applicant conceded time-barred leave application.
Appeal procedure – extension of time – rule 10 Court of Appeal Rules – application for extension is governed by good cause and Court's discretion; rule 45 (time for leave to appeal) inapplicable to extension applications; application struck out where applicant conceded underlying time-barred status.
5 October 2022
A conditional stay of execution was granted pending appeal where the applicant showed risk of substantial loss and undertook to provide bank guarantees.
Court of Appeal — Stay of execution — Rule 11(5) Tanzania Court of Appeal Rules — requirement of substantial loss and security — undertaking to furnish bank guarantee — balance of convenience — conditional stay pending appeal.
3 October 2022
September 2022
Review application dismissed for failing to show a manifest error on the face of the record.
Civil procedure – Review under Rule 66(1)(a) – Manifest error on the face of the record – Requirement to identify an obvious, patent mistake; review not a rehearing or re-assessment of evidence.
29 September 2022
Cautioned statement recorded with other officers vitiated; uncorroborated co‑accused evidence insufficient—appellant's conviction quashed.
Criminal law – Admissibility of cautioned statements – voluntariness and right to privacy; cautioned statement recorded in presence of other officers vitiates confession. Evidence of co‑accused requires corroboration; uncorroborated recent‑possession link insufficient. Proof beyond reasonable doubt — conviction quashed when key evidence expunged.
29 September 2022
Proceedings conducted without a section 256A transfer are a nullity; conviction quashed and matter remitted for proper retrial.
* Criminal procedure – Transfer of cases under section 256A Criminal Procedure Act – transfer must be issued before plea taking and preliminary hearing; absence of transfer vitiates jurisdiction. * Overriding objective – cannot cure mandatory jurisdictional defects. * Revisional powers – quash proceedings, conviction and sentence; remit information to High Court for retrial.
29 September 2022
The appellant's armed robbery conviction was upheld on credible eyewitness evidence despite missing exhibit and phone-provider testimony.
Criminal law – Armed robbery – sufficiency of prosecution proof by eyewitnesses; admissibility and effect of non-tendered exhibits; calling of mobile service providers not always necessary; credibility and minor discrepancies; no legal requirement to remind accused of charge before judgment.
28 September 2022
Conviction for child rape upheld on credible child testimony, medical PF3 and accused's voluntary confession.
Criminal law – Rape of a child – Child’s unsworn evidence and corroboration by medical PF3; Cautioned statement – voluntariness and admissibility; Defence alibi as afterthought; Compliance with s.312 CPA; Hearsay v direct evidence; Proof of age for statutory rape.
1 September 2022
An invitee's occupation cannot extinguish the host's ownership; limitation and abandonment did not bar the owner's claim.
Land law — limitation of actions; law of limitation does not defeat a host’s rights where occupier is an invitee — invitee cannot acquire ownership by long occupation; abandonment under Village Land Act s.45 requires statutory proof and procedure; evidentiary burden to show dispossession/abandonment.
1 September 2022
March 2022
Typographical and documentary omissions in an appeal are curable; non-served co-judgment debtor who does not appeal does not automatically render appeal incompetent.
* Civil procedure — Appeals — Notice of appeal — Substantial compliance with Form D and Rule 83(3)/(6) — Typographical error in case description curable under Rule 111. * Civil procedure — Appeals — Service of notice of appeal — Rule 84(1) — Whether failure to serve non-appealing co-judgment debtor renders appeal incompetent. * Civil procedure — Record of appeal — Rule 96(1)(k), (6) and (7) — Omission of documents (written submissions in extension application) curable by supplementary or additional record.
29 March 2022
February 2022
An unsigned, unstamped or incorrect High Court transfer order renders a magistrate's determination null and void.
Criminal procedure – Transfer of appeals – Section 45(2) Magistrates' Courts Act – Formal High Court transfer required – Unsigned/unstamped/wrongly‑referenced transfer order vitiates jurisdiction; proceedings nullity and judgment quashed.
25 February 2022
An unsigned and undated trial judgment violated statute, rendering trial and first appeal null and remitting the matter for proper judgment.
* Criminal procedure – appellate jurisdiction – new grounds of appeal not raised in High Court – general rule that second appeals cannot raise new factual grounds unless pure point of law. * Criminal procedure – change of magistrate – section 214(1) CPA – successor magistrate may take over only where predecessor unable to complete trial and reasons recorded. * Criminal procedure – writing of judgment – section 312(1) CPA – judgment must contain points for determination, reasons, be dated and signed by presiding officer. * Judgment – unsigned and undated judgment is a nullity; consequent nullity of appellate proceedings and remedial remittal.
25 February 2022
Appellants' murder convictions upheld: eyewitness recognition credible despite delayed reporting and absence of post‑mortem.
* Criminal law – Murder – Identification and credibility of eyewitnesses – Recognition evidence by relatives/villagers in daylight. * Criminal procedure – Delay in naming suspects – Fear, investigative transfer and delay do not automatically discredit witnesses. * Evidence – Post‑mortem not indispensable where eyewitness and circumstantial evidence establish cause of death. * Duty of custodians/officials – Village leaders’ failure to protect person in custody. * Civil/criminal appeals – Abatement of appeal on death of appellant (Court of Appeal Rules).
25 February 2022
The appellant’s conviction was quashed due to weak, unreliable evidence and irregularly admitted/read exhibits.
* Criminal procedure – appellate jurisdiction – grounds not raised/decided at lower courts ordinarily not entertained on appeal. * Evidence – exhibits – documentary and physical exhibits must be read in court; failure to do so is incurable and leads to expungement. * Medical evidence – clinical officer competent to examine and prepare PF3. * Cautioned statements – no mandatory requirement to call justice of the peace or tender extrajudicial statement to support; prosecution decides which witnesses to call. * Credibility – victim’s uncorroborated testimony must be critically scrutinised; conviction cannot rest on weak or unreliable evidence.
25 February 2022
Recognition identification and corroboration sustained convictions; identification parade registers and child’s evidence expunged for procedural defects.
* Criminal law – identification by recognition – familiarity and lighting as factors eliminating mistaken identity (Waziri Amani; Jumapili Msyete). * Criminal procedure – identification parade – registers must be read over in court; failure leads to expungement though oral evidence may corroborate. * Evidence Act s.127(2) – child witness must promise to tell the truth; failure renders testimony inadmissible. * Appellate procedure – new factual grounds not raised in lower appellate court are not entertained on second appeal.
25 February 2022
The applicant's statutory rape conviction was upheld; age, credibility, corroboration and delay explanation were sufficient.
* Criminal law – Statutory rape (s.130(2)(e) Penal Code) – proof of age essential and may be given by the victim. * Evidence – child witnesses (s.127(2) Evidence Act) – promise to tell truth required; omission to record exact question not necessarily fatal. * Evidence – delay in complaint – threats can justify delayed disclosure. * Medical evidence (PF3) – late examination may undermine probative value and trial court may accord it little weight. * Appellate review – credibility assessment is primarily trial court's function; appellate court may evaluate unconsidered defence evidence if necessary.
25 February 2022
Second‑bite leave struck out where the proposed ground was not raised below and no illegality was apparent on the record.
* Civil procedure – leave to appeal – discretionary remedy – granted only for arguable or important points of law or where illegality is apparent on the face of the record. * Appellate jurisdiction – Court of Appeal will not ordinarily entertain grounds not raised or decided in lower courts; jurisdictional limitation under Appellate Jurisdiction Act. * Fair trial – allegation of denial by refusal to allow re‑examination must be raised below and be apparent on the record to be considered on appeal.
25 February 2022
Conviction for statutory rape upheld despite expunged child evidence where age and penetration proved by other witnesses.
Criminal law – statutory rape – proof of age and penetration – child witness voir dire (s.127 Evidence Act) – irregular voir dire leading to expunging child’s evidence – conviction sustainable on collateral evidence – appellate jurisdiction to entertain new grounds.
25 February 2022
Failure to name the person targeted by violence in an armed robbery charge renders the trial unfair and conviction null.
* Criminal law – Armed robbery (s.287A Penal Code) – essential ingredient requires use or threat of violence directed at a person – particulars must state person targeted. * Criminal procedure – Form and content of charge (ss.132, 135 CPA) – particulars must disclose essential elements to enable fair defence. * Defective charge – omission of person targeted is fatal, prejudicial and not curable under s.388 CPA. * Remedy – proceedings and judgments nullified; conviction quashed and sentence set aside; release ordered under revisional powers (s.4(2) AJA).
24 February 2022
Failure to attach the High Court's drawn order under Rule 49(3) rendered the application for leave incompetent and it was struck out.
* Civil procedure – Court of Appeal Rules 2009 r.49(3) – mandatory requirement to accompany an application for leave with the decision to be appealed and, where relevant, the High Court's order refusing leave – failure to attach extracted order renders application incompetent. * Procedural compliance – a High Court ruling or proceedings do not substitute for an extracted order required by the Rules. * Application for leave – consequence of non-compliance – strike out with costs.
24 February 2022
Rule 62 permits informal or written references without attaching the full record; preliminary objection dismissed and matter fixed for hearing.
Civil procedure – Reference from single Justice – Rule 62(1) – informal or written application to Registrar within seven days – no requirement to attach full record unlike revision – preliminary objection for want of record dismissed.
24 February 2022
Failure to involve and instruct assessors and inclusion of extraneous facts vitiated the trial; conviction and death sentence quashed.
* Criminal procedure – Assessors – Failure to allow accused to express views on selected assessors and failure to explain assessors' role vitiates trial; * Evidence – Visual and voice identification – need for caution and supportive circumstances; * Evidence – Admissibility of cautioned statement and testimony of witness not read or listed at committal; * Judgments – Inclusion of extraneous facts not in evidence is fatal irregularity; * Appellate jurisdiction – Power to quash conviction and decline retrial when prosecution case is weak.
24 February 2022
23 February 2022
Failure to lodge required supplementary record and prove timely service rendered the appeal incompetent and struck out.
* Appellate procedure — Supplementary record of appeal — Rule 96(7) — omitted documents must be new to record; * Proof of service — letter requesting certified proceedings — document must identify the specific letter; * Time limits — service of copy of letter to respondent co-extensive with 30-day period for applying for certified proceedings (Valambhia); * Consequence — failure to comply renders record incomplete and appeal incompetent; appeal struck out.
21 February 2022
Procedural and summing-up defects involving assessors rendered the trial unfair; conviction quashed and retrial ordered.
Criminal procedure — Assessors — mandatory selection and recordation after plea of not guilty (ss. 283, 285 CPA); right to be afforded opportunity to object to assessors; Practice — informing/explaining assessors’ roles; Summing up — duty to direct assessors on vital legal points (malice aforethought, overt act, circumstantial evidence, visual identification, corroboration); Irregular summing up and inclusion of matters not supported by evidence vitiates trial; Remedy — nullify proceedings, quash conviction and order retrial (s. 4(2) AJA).
18 February 2022
Appellant’s unsworn child-victim testimony corroborated by medical evidence upheld; PF3 expunged; appeal dismissed.
* Criminal law – Sexual offences – Reliance on child victim’s unsworn testimony – requirement for corroboration by medical or other evidence. * Evidence – PF3/medical report improperly admitted if contents not read out; oral medical testimony may still prove penetration. * Appellate procedure – second appeal limited to points of law under s.6(7)(a) AJA; concurrent findings of fact will not be disturbed absent misdirection or miscarriage. * Competence of witnesses – relative witnesses competent unless collusion shown. * Delay in arrest – explained absence and investigative flaws may negate prejudice to defence.
17 February 2022
Court dismissed appeal, holding new grounds not raised below are inadmissible and conviction upheld on sufficient evidence.
* Criminal appeal – jurisdiction to entertain new grounds – section 4(1) AJA – new grounds not raised below are ordinarily not entertainable unless pure points of law. * Evidence – age in charge sheet or pre‑evidence particulars not proof of age; PF3 not read out is expunged. * Criminal law – sexual offences – victim’s testimony corroborated by parent and medical evidence can prove rape. * Appellate review – omission by first appellate court to consider defence may be cured where trial court properly evaluated defence.
17 February 2022
Court may infer victim's age from surrounding circumstances in statutory rape; conviction and 30-year sentence upheld.
* Criminal law – Statutory rape (s.130(2)(e) Penal Code) – Proof of victim’s age – whether direct evidence required or age may be inferred under s.122 Evidence Act. * Criminal procedure – Appeals – new factual grounds not raised in first appellate court cannot be entertained on further appeal. * Evidence – identification, prompt complaint and medical evidence as corroboration in sexual offences. * Sentencing – where age inferred but not positively proved to be under ten, life sentence inappropriate; 30-year sentence upheld.
17 February 2022
An unequivocal guilty plea supported conviction; late language complaints and allegations of unfair trial were unavailing.
* Criminal law – guilty plea – requirements for valid plea and conviction without trial – applicability of Michael Adrian Chaki criteria. * Criminal procedure – language and interpretation – failure to raise language difficulty at arraignment and afterthought complaints. * Evidence – denials of non‑ingredient facts do not vitiate an otherwise unequivocal guilty plea. * Criminal appeals – issues of unfair trial and proof beyond reasonable doubt not available where accused pleaded guilty.
16 February 2022
An unequivocal guilty plea establishing all elements of statutory rape upheld despite irregular admission of exhibits.
Criminal procedure – plea of guilty – requirements for an unequivocal plea under s.228 CPA – statutory rape – proof of age where age admitted – improper tendering of exhibits not vitiating plea-based conviction.
16 February 2022
Extension granted where delay was due to the High Court’s late provision of certified records and alleged facial illegalities.
Civil procedure — Court of Appeal Rules, Rule 10 — extension of time — good cause — delay caused by late delivery of certified records — alleged illegalities on the face of the record (assessors’ opinions, irregular changes, tribunal jurisdiction).
16 February 2022
Defective summing up (failure to explain visual identification and inclusion of extraneous matter) vitiated conviction; retrial ordered.
* Criminal procedure – Summing up to assessors – Duty to explain law and vital points of law (including visual identification) when assessors are involved. * Evidence – Visual identification at night – Factors to be explained to assessors and necessity of eliminating possibility of mistaken identity. * Criminal procedure – Summing up – Prohibition on introducing extraneous matters not supported by evidence; such inclusion may vitiate proceedings. * Remedy – Where summing up is defective and assessors uninstructed on vital law, conviction may be quashed and retrial ordered.
15 February 2022
Failure to file a statutory notice of intention to appeal deprived the High Court of jurisdiction; its judgment was nullified.
* Criminal procedure – Appeals – Notice of intention to appeal – Requirement under section 361(1)(a) CPA to give written notice within ten days – Mandatory jurisdictional condition. * Criminal procedure – Extension of time – Failure to apply for extension renders appeal to High Court a nullity. * Appellate jurisdiction – Statutory in origin – proceedings heard without compliance with statutory preconditions are void. * Appellate Jurisdiction Act s.4(2) – Court’s power to nullify proceedings and judgment.
15 February 2022
Charging the applicant under a repealed statute vitiates prosecution, warranting nullification and immediate release.
Criminal law – indictment must cite the valid statute – prosecution under a repealed law vitiates trial; incurable defect under section 388(1) CPA; revisional powers under section 4(2) AJA to nullify proceedings, quash conviction and order release.
15 February 2022
The respondent proved child rape beyond reasonable doubt; clinical officer competent; PF3 expunged; appeal dismissed.
* Criminal law – Rape of a child – proof beyond reasonable doubt – victim and mother testimony corroborated by clinical officer. * Evidence – Competence of clinical officer to conduct examination and testify. * Evidence – Irregular admission of PF3 (not cleared or read over) and its expungement. * Evidence – Credibility of family witnesses; single credible witness may suffice. * Criminal procedure – Failure to call certain prosecution witnesses or tender a cautioned statement is not necessarily fatal.
15 February 2022