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.
70 judgments

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70 judgments
Citation
Judgment date
October 2014
Conviction quashed where information was defective and the guilty plea and sentencing procedures were fundamentally irregular.
Criminal procedure – defective information – omission to name deceased; statutory requirements of s.135 CPA; plea-taking – requirements of s.282 CPA and need to record accused’s own words; inadmissibility of counsel admitting facts on accused’s behalf; conviction after mitigation and improper sentencing; relief by quashing conviction and setting aside sentence; DPP discretion to re‑charge.
30 October 2014
Statutory rape conviction upheld where victim's age was established by unchallenged evidence; second-appeal issues not entertained.
* Criminal law – Statutory rape – victim's age established by unchallenged testimony and corroboration by accused – failure to cross-examine implies acceptance of evidence. * Evidence – Parental testimony on child's age treated as cogent evidence. * Appellate procedure – Second appeal cannot entertain matters not raised or decided in the first appellate court.
30 October 2014
Retracted confession was admissible and corroborated; malice aforethought established, appeal dismissed.
Criminal law – admissibility of extra-judicial/confessional statement – voluntariness and trial-within-trial; Retracted confession – need for independent corroboration; Malice aforethought – inference from weapon used, injuries inflicted, motive and conduct; Appellate review of credibility findings.
30 October 2014
Failure to enter a conviction before sentencing under section 235(1) renders the sentence and subsequent appeals incompetent; record remitted for lawful conviction and sentencing.
Criminal procedure – mandatory requirement to enter conviction before sentence (s.235(1) Criminal Procedure Act) – failure to enter conviction renders sentence and judgment a nullity – appeal based on incompetent judgment is incompetent – Court of Appeal’s revisional powers (s.4(2) Appellate Jurisdiction Act) to nullify and remit for proper conviction and sentencing – credit for time served.
30 October 2014
Court upheld rape conviction of a child’s assailant: child identification corroborated and voir dire procedure proper.
Criminal law – rape of a child – visual identification by a child of tender years; corroboration by other witness and accused’s flight; voir dire and reception of unsworn testimony under s.127 Evidence Act; concurrent findings of fact upheld.
29 October 2014
Application for extension to appeal struck out as incompetent where no competent appeal had been instituted against the High Court decision.
Criminal procedure – extension of time to file appeal – competence of appeal – where High Court had found no competent appeal because applicant failed to institute fresh appeal after extension; Rule 47 Court of Appeal Rules (applying first to High Court) – Rule 10 (good cause) – applicant advised to apply to High Court for extension and fully explain delay.
29 October 2014
Application for extension of time to appeal struck out as incompetent; applicant must first seek High Court extension.
Criminal procedure — extension of time to file appeal — Court of Appeal Rules, 2009 Rule 10 (good cause) and Rule 47 (application to High Court first) — requirement to file fresh Notice and Petition under s.361(1)(a),(b) Criminal Procedure Act — incompetence of appeal where no competent appeal instituted.
29 October 2014
A trial court’s suo motu jurisdictional ruling without hearing parties is a fundamental procedural error, so appeal allowed and matter remitted.
* Civil procedure – court raising issues suo motu – limits under Order XIV Rule 5 CPC – requirement to afford parties opportunity to be heard (audi alteram partem). * Administrative law/procedure – challenge to disciplinary decisions of Inspector General of Police – procedural route (ordinary suit v. judicial review) left for trial court to determine on merits. * Jurisdictional error – decision based on unpleaded issue – nullity and remedy by quashing and remittal.
28 October 2014
Applicant failed to show good cause for delay or arguable grounds for review; extension of time was refused.
* Criminal procedure – extension of time – Rule 10 Court of Appeal Rules 2009 – requirement to show good cause for delay. * Duty to show efforts to obtain judgment copy before complaining of non‑supply. * Review applications – necessity to demonstrate prospects of success under Rule 66(1)(a)–(e) when seeking extension.
28 October 2014
Appeal dismissed: procedural lapses curable and eyewitness evidence supported malice aforethought for murder.
Criminal procedure — memorandum of matters not in dispute — duty to read over and explain (s192(3)) — failure curable if no prejudice (s388(1)); Evidence — post‑mortem date clerical error; Impeachment — prior inconsistent statement and section 169; Credibility — eyewitness identification and corroboration; Murder — malice aforethought inferred from weapon and wound; Assessors — judge may differ but must give reasons.
28 October 2014
Failure to read the memorandum aloud was curable; credible eyewitness evidence and injuries supported malice aforethought; appeal dismissed.
Criminal procedure – s192(3) memorandum of matters not in dispute must be read over and explained – failure curable under s388(1) if no prejudice; Evidence – admissibility and use of prior inconsistent/cautioned statements for impeachment; Credibility of eyewitnesses; Malice aforethought may be inferred from use of a dangerous weapon and injury location; Clerical errors in exhibits do not necessarily affect admissibility.
28 October 2014
Trial court erred by deciding a suo motu jurisdictional issue without hearing parties; judgment quashed and remitted.
Administrative law – challenge to disciplinary dismissal – availability of ordinary civil suit v. judicial review; Civil procedure – court raising issues suo motu under Order XIV Rule 5 – requirement to afford parties opportunity to address amended or additional issues; Natural justice – audi alteram partem; Remedy – quashing and remitting for trial before different judge.
27 October 2014
Application to strike out respondent’s notice of appeal dismissed; no statutory duty to chase the court registry for transcripts.
Civil procedure — application to strike out notice of appeal under Rule 89(2) — failure to obtain copies of proceedings after request — no statutory duty to remind Registry — once Rule 83 complied with, reminder is practical not mandatory.
24 October 2014
Failure to chase the registry does not justify striking out a notice of appeal where Rule 83 has been complied with.
* Appellate procedure – Application to strike out notice of appeal under Rule 89(2) – Whether failure to follow up registry for copies of proceedings justifies striking out. * Court of Appeal Rules – Rule 83 compliance – once complied with, an intending appellant’s position is secure. * Registry obligations – Practical prudence to remind registry but no statutory duty to chase copies of proceedings.
24 October 2014
Extension of time to seek revision denied where non‑party applicant lacked viable remedy and grant would be futile.
Civil procedure – Extension of time – Revision – Discretion to extend time – Promptness after knowledge – Non‑party to earlier proceedings lacks locus to overturn matrimonial findings by revision – Alternative remedies (Rule 85 application; civil action) may render extension futile.
24 October 2014
Extension of time to seek revision refused where applicant, not party to earlier proceedings, had alternative remedies and likely no success.
Civil procedure — Extension of time to file revision — Applicant not party to earlier proceedings — Revision not appropriate remedy — Alternative remedies include Rule 85 application to set aside sale, civil action for property, or damages for adultery — Court may refuse extension as futile.
23 October 2014
Conviction based solely on uncorroborated cautioned and extra-judicial statements, without proper assessors’ involvement, is unsafe.
Criminal law – murder – reliance on cautioned and extra-judicial statements; corroboration required – evidence requiring corroboration cannot corroborate other similar evidence; assessors’ involvement – trial-within-trial ruling must be delivered in court and assessors must be properly involved and directed; delay in producing accused to court and allegations of torture undermine voluntariness; prosecution duty to call readily available material witnesses.
22 October 2014
Conviction based on uncorroborated cautioned and extra-judicial statements was unsafe; appeal allowed and conviction quashed.
* Criminal procedure – admissibility of cautioned and extra-judicial statements – corroboration rules – a confession requiring corroboration cannot corroborate another such statement. * Trial with assessors – necessity to involve assessors in all stages (except conduct of trial within trial) and to direct them on dangers of uncorroborated statements. * Voluntariness of statements – delay in bringing accused before court and allegations of torture undermine reliability. * Prosecution duty – calling available witnesses connected to transaction; failure permits adverse inference and may render conviction unsafe.
22 October 2014
Uncorroborated statements and procedural defects (delay, assessors' exclusion) created reasonable doubt; conviction quashed.
Criminal law – admissibility and weight of cautioned statements – trial-with-assessors requirement (s.265 CPA) – extra-judicial/confessional statements and need for corroboration – voluntariness where torture alleged and delay before court (s.32(2) CPA) – prosecution’s duty to call material witnesses; adverse inference.
22 October 2014
Court upheld conviction, finding visual identification reliable due to prolonged close struggle and corroborating evidence.
Criminal law – Visual identification – Waziri Amani factors: duration, proximity, lighting and prior knowledge; corroboration by witnesses and police evidence; conviction for armed robbery upheld.
21 October 2014
Appeal dismissed: identification and penetration proved; procedural date variance and missing non‑eyewitnesses immaterial.
Criminal law – Rape: proof of penetration (s.130(4) Penal Code) and corroboration by medical evidence; Identification: familiar witness and contemporaneous torch-assisted ID; Evidence Act: no fixed number of witnesses (s.143) and where failure to call non‑eyewitnesses does not attract adverse inference; Criminal Procedure Act s.234(3) – variance in time immaterial; Burden of proof – remains on prosecution, presumption of innocence maintained.
21 October 2014
Preliminary hearing irregularity limited; defective ID parade expunged, but visual and circumstantial evidence upheld convictions and adjusted sentences.
Criminal procedure – Preliminary hearing non-compliance with s.192(3) CPA vitiates only the preliminary hearing; Identification parade – PGO No.232 procedural breaches render parade evidence worthless; Visual identification – daylight identification and corroborative circumstantial evidence can prove identity beyond reasonable doubt; Sentencing – life sentence for rape of a person above ten may be excessive; Compensation – trial court may award compensation but appellate order for distress to enforce it unlawfully exceeded trial court's direction; Robbery – deprivation of property while committing rape with a weapon constitutes armed robbery.
20 October 2014
Armed robbery convictions quashed for inadequate visual identification and misapplied recent-possession doctrine.
* Criminal law – Visual identification – witness must describe conditions of observation, source and intensity of light, clothing, distance and duration of observation (Waziri Amani factors). * Criminal law – Recent possession – prosecution must positively identify recovered property as the complainant's; common trade items without marks or serial numbers do not satisfy the requirement (Joseph Mkumbwa principles). * Conviction – Where identification and recent-possession proof are inadequate, conviction and sentence must be quashed.
17 October 2014
The appellants' armed robbery convictions quashed due to defective charge and insufficient proof of recent possession.
Criminal law – armed robbery (s. 287A Penal Code) – particulars must disclose essential elements (threat/violence) – doctrine of recent possession – requirement of positive identification and intact chain of custody – discretion as to retrial where evidence is insufficient.
17 October 2014
Conviction for armed robbery unsafe where charge omitted essential elements and recent possession not proved by broken chain of custody.
* Criminal law – particulars of charge – essential elements – section 287A requires pleading the threat/violence element. * Criminal law – doctrine of recent possession – requirements: property found with suspect, property proved to belong to complainant, property proved stolen, and recently stolen. * Evidence – chain of custody – continuity and identification of recovered exhibit must be established. * Procedure – retrial considerations where prosecution case deficient; conviction unsafe where reasonable doubt persists.
17 October 2014
Appeal allowed: conviction quashed for unsafe identification and inadequate descriptive corroboration to police.
* Criminal law – Identification evidence – Visual identification at night – Adequacy of lighting and description – Single eyewitness reliability – Immediate report to police without descriptive particulars insufficient to corroborate identification.
15 October 2014
September 2014
Applicant's affidavit expunged for defective jurat; remaining affidavit failed to show "good cause" so extension denied.
* Civil procedure – Affidavits – Jurat must state place and date; failure to do so renders affidavit incurably defective under section 8 of the Notaries Public and Commissioner for Oaths Act. * Court of Appeal Rules 2009 – Rule 49(1): notices of motion may be supported by affidavits of other persons. * Rule 10: extension of time requires demonstration of "good cause" by satisfactory evidential reasons in the supporting affidavit.
19 September 2014
Extension to file review refused after applicant's affidavit was expunged for defective jurat and supporting affidavit failed to show good cause.
Extension of time — application for review — defective affidavit — jurat must state place of attestation per section 8 Notaries Public and Commissioners for Oaths Act — expungement of defective affidavit — Rule 49(1) affidavit by third party — requirement to show independent reasons/good cause under Rule 10.
19 September 2014
Applicant failed to show good cause for an extension to seek review; generalized claims of lost filings insufficient.
Criminal procedure — extension of time under Rule 10 — requirement to show good cause; review applications — grounds for review under Rule 66(1) — necessity to link excuse for delay to enumerated grounds; lost/misplaced registry documents — need for credible evidence (stamped filings or registry affidavits).
18 September 2014
An appeal is incompetent and must be struck out if mandatory trial exhibits are omitted from the record of appeal.
Civil procedure — Appeal competency — mandatory inclusion of trial exhibits in record of appeal — Rule 96(2) Court of Appeal Rules 2009 — exclusion requires leave under Rule 96(3) — 14‑day cure under Rule 96(6) — failure to include exhibits is fatal to appeal.
18 September 2014
Delay by prison authorities amounted to good cause to extend time to file a notice of appeal for an incarcerated applicant.
Court of Appeal — extension of time under Rule 10 — notice of appeal — Rule 68 time limit — incarcerated appellants — delay by prison authorities as good cause — supporting affidavits and precedents.
18 September 2014
Preliminary hearing valid; non-compliant PF3 expunged; concurrent eyewitness evidence upheld conviction for robbery with violence.
Criminal procedure – Preliminary hearing – compliance with s.192(3) CPA; Evidentiary law – medical report (PF3) – requirements of s.240(3) CPA and expungement if non-compliant; Proof of robbery with violence – weight of concurrent eyewitness evidence and red-handed arrest; Prosecution’s choice of witnesses – failure to call investigator not necessarily fatal; Appellate review – reluctance to disturb concurrent findings of fact.
17 September 2014
Concurrent factual findings upheld; defective PF3 expunged, but conviction for robbery with violence sustained.
* Criminal procedure – Preliminary Hearing – compliance with section 192(3) Criminal Procedure Act – memorandum read, explained and signed. * Evidence – PF3 (medical form) – admissibility – non-compliance with section 240(3) Criminal Procedure Act – PF3 expunged. * Criminal law – robbery with violence – proof of ingredients by complainant and independent witnesses – concurrent findings of fact upheld. * Evidence – minor inconsistencies in witness accounts do not necessarily vitiate conviction where core facts are consistent. * Prosecution discretion – choice of witnesses – failure to call investigator not fatal where case proved. * Right to call witnesses – allegation of denial without contemporaneous record is an afterthought.
17 September 2014
Failure to institute an appeal within sixty days (and not seeking record or extension) deems the notice of appeal withdrawn.
* Civil procedure – Appeal procedure – Rule 90(1) Court of Appeal Rules 2009 – time for instituting appeals and proviso excluding time for preparation of record. * Civil procedure – Enlargement of time – need to apply for extension where leave to appeal is pending. * Civil procedure – Effect of failure to institute appeal within prescribed time – Rule 91(a) deeming notice of appeal withdrawn and costs consequences. * Practice – Written submissions – compliance with Rule 106(2) requirements for stating material facts and issues.
17 September 2014
Failure to institute appeal within 60 days without applying for record or extension deems notice of appeal withdrawn.
* Civil procedure – Appeals – Rule 90(1) and proviso re: application for copy of High Court proceedings – requirement to apply in writing within 30 days to exclude time. * Civil procedure – Appeals – sixty-day limitation to institute appeal and Rule 91(a) consequence: deemed withdrawal of notice of appeal for failure to institute. * Civil procedure – Leave to appeal pending in High Court does not suspend sixty-day time limit; party should seek enlargement of time under the Rules. * Practice – Written submissions must state material facts and issues per Rule 106(2).
16 September 2014
A guilty plea confines appeal to sentence; mandatory life for rape of a child under ten upheld.
* Criminal law – guilty plea – scope of appeal limited to extent or legality of sentence – s.360(1) CPA. * Evidence – defects (PF3, blood proof) immaterial once accused pleads guilty and admits facts. * Criminal procedure – variance in dates curable under s.234(3) CPA. * Sentencing – mandatory life imprisonment for rape of child under ten – s.131(3) Penal Code.
16 September 2014
Court quashed committal for contempt where applicants were condemned unheard and registrar unlawfully varied the judge's order.
Contempt of court — requirement to frame and record substance of charge, read charge and call accused to show cause, right to be heard — variation of judicial order by District Registrar — limits of Registrar's powers under section 327 CPA — revisional jurisdiction under section 4(3) AJA — necessity to specify legal basis (eg. Penal Code s.114) when committing to imprisonment.
15 September 2014
Application for extension struck out because notices misstated the High Court judgment date, rendering the notice of appeal invalid.
Court of Appeal Rules – Form A and Form D – mandatory requirement to state correct date of High Court decision – invalid Notice of Appeal defeats jurisdiction to grant extension of time – defective notices incurably defective for purposes of extension application.
12 September 2014
An extension to apply for review requires good cause and an indication of which Rule 66(1) grounds the review will rely on.
* Civil procedure – extension of time – Rule 10 Tanzania Court of Appeal Rules; * Review jurisdiction – Rule 66(1) – grounds for review (manifest error on face of record; deprivation of hearing; nullity; lack of jurisdiction; judgment procured illegally/fraud/perjury) – must be pleaded or shown at extension stage; * Review is not an appeal – proposed review must prima facie relate to Rule 66(1) grounds; * Review jurisdiction existed in case law before 2009 Rules.
11 September 2014
Application for extension struck out because defective notices cited an incorrect High Court judgment date, depriving jurisdiction.
Extension of time — Notice of Motion and Notice of Appeal must correctly state the date of the decision — Rule 48(2)/Form A and Rule 83(6)/Form D — invalid Notice of Appeal deprives Court of jurisdiction — defective notices not curable in present application.
10 September 2014
Omission of vital trial exhibits from the record renders an appeal incompetent and must be struck out.
Appeal procedure – record of appeal – Rule 96(1) mandatory inclusion of documents adduced at trial; failure to include vital exhibits renders appeal incompetent; supplementary record permissible only to add to a complete record; Rule 96(6) 14-day right to include omitted documents; incompetent appeal results in striking out appeal and dependent cross-appeal.
9 September 2014
Prison administrative failures (lack of typing resources) amounted to good cause to grant extension of time for filing review.
* Civil procedure – Extension of time – Rule 10 Court of Appeal Rules – "good cause" – discretion to enlarge time; affidavit by prison officer as competent support where applicants' affidavit expunged; prison administrative failures (scarcity of typing materials, single typewriter) as sufficient cause for delay.
8 September 2014
An incomplete record of appeal filed without leave renders the appeal incompetent and is struck out.
Civil procedure — Appeals — Record of appeal — Requirement to include trial court proceedings per Rule 96(2) — Exclusion of documents requires direction under Rule 96(3) — Remedy under Rule 96(6) to include omitted documents — Incomplete record renders appeal incompetent.
8 September 2014
Prisoners' delay caused by prison administrative constraints constituted good cause to grant extension of time to file review.
Criminal procedure — Extension of time under Rule 10 — "Good cause" requires evidential reasons — Prison officer's affidavit acceptable support under Rule 49(1) — Administrative constraints in custody (scarcity of stationery, single typewriter, delay in supply of judgment) can constitute good cause.
4 September 2014
Failure to expressly consider mitigating factors (guilty plea, time in custody) justified reducing the sentence from 15 to 9 years.
Criminal law — Sentencing — Requirement that trial court expressly state consideration of legitimate mitigating factors (e.g., guilty plea, pre-sentence custody) — Failure to do so creates doubt to be resolved in favour of appellant — Appellate interference and reduction of sentence.
4 September 2014
Court granted extension of time to file revision of CMA award and declined to entertain a time-bar objection where extension was sought.
* Labour procedure – Extension of time – Application for enlargement to file revision of CMA award – Granting extension where appropriate and preliminary objection inapt.* Civil procedure – Preliminary objections – Objection of time-bar raised despite pending extension application is unnecessary.* Scope of adjudication – Court will not determine substantive merits where affidavit only pleads extension of time.
3 September 2014
August 2014
Prisoner’s late receipt of High Court decision due to prison administration constituted sufficient cause for extension of time.
Criminal procedure – Extension of time under Rule 10 – Delay in filing notice of appeal – Late communication of High Court decision to a prisoner beyond applicant’s control constitutes sufficient cause – Officer in-charge to comply with Rule 75(1).
12 August 2014
Application for security for costs struck out for wrong rule citation and lack of Court of Appeal jurisdiction over Labour Court execution.
Labour law – enforcement of Labour Court decrees; Court of Appeal jurisdiction – security for costs; procedural competency – wrong citation of Court of Appeal Rules (rule 38) and inapplicability of rule 120 where no civil appeal instituted; Rule 48(3) Labour Court Rules – execution may proceed despite intended appeal; preliminary objection – application struck out.
7 August 2014
Court struck out applicant's security-for-costs application for incompetence due to wrong rule citation and lack of jurisdiction.
Civil procedure — jurisdiction — Court of Appeal improperly moved; wrong citation of rules renders application incompetent; rule 120 (security in civil appeals) applies only after appeal is instituted; Labour Court Rules (r.48(3)) permit enforcement of decrees despite intended appeal.
7 August 2014
Court quashed High Court ruling that improperly combined leave to file a notice and leave to appeal in a land matter.
Land law — procedural compliance — leave to appeal in land matters must be sought under Section 47(1) of the Land Disputes Courts Act; Appellate procedure — Section 11(1) AJA is for leave to file a notice of appeal; Irregular application combining different statutory prayers — Court may, under Section 4(2) AJA, quash the High Court ruling; Failure to observe Section 47(1) renders an appeal incompetent.
6 August 2014