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.
121 judgments

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121 judgments
Citation
Judgment date
December 2018
Appellate court affirmed eight-year manslaughter sentence despite generalized mitigation analysis due to brutal, disproportionate attack.
Criminal law – Manslaughter – Sentencing – Mitigating factors must be considered specifically – Appellate interference limited where aggravating circumstances (brutal attack, lethal weapon, disproportionate force) justify sentence.
30 December 2018
Appellant failed to prove allocation of 300 acres on the balance of probabilities; appeal dismissed with costs.
* Land law – proof of allocation/ownership – claimant must prove allocation and size on balance of probabilities (Evidence Act ss.110–111). * Civil procedure – preliminary objection based on disputed facts is improper; factual disputes over service should be pursued under Rule 89(2), not as a pure preliminary point. * Evidence – documentary and oral evidence must be specific and coherent to establish land size and ownership.
14 December 2018
Appellant failed to prove allocation of 300 acres; appeal dismissed for insufficient evidence; costs awarded to respondent.
Land law – proof of ownership/allocation – burden and standard of proof in civil cases (s.110–111 Evidence Act) – documentary evidence insufficient to establish 300 acres – preliminary objection based on service dates involves facts and should be pursued under Rule 89(2).
14 December 2018
Sentence reduced after trial judge failed to consider appellant's mitigating factors and time already served.
Criminal law – Sentencing – Mitigating factors – First offender and pre-trial custody – Appellate interference where sentence is manifestly excessive – R v. Mohamed Ali Jamal applied.
14 December 2018
Appellate court reduced a manslaughter sentence for failure to expressly consider material mitigating factors.
* Criminal law – Sentencing – Requirement for trial court to expressly consider and specify mitigating and aggravating factors – Generalised statements insufficient. * Appellate review – Interference with sentence only where trial court acted on wrong principle or overlooked material factors. * Mitigating factors – time in remand, plea of guilty and dependants as relevant considerations.
14 December 2018
Sentence reduced where trial judge failed to consider mitigating factors including guilty plea, youth and time served.
Criminal law – Sentencing – Mitigating factors – guilty plea, first offender status, time served and youth – appellate interference where trial court overlooks material mitigation.
14 December 2018
Sentence reduced where trial court failed to consider mitigating factors and evidence of self-defence.
Criminal law – Manslaughter – Sentencing – Failure to consider mitigating factors individually – Evidence of provocation and self-defence – Appellate interference and reduction of sentence.
14 December 2018
Appellant failed to prove on the balance of probabilities allocation of the claimed 300 acres; appeal dismissed.
Civil procedure – Preliminary objections – factual dispute as to service of record of appeal cannot be treated as a pure point of law; should be pursued under rule to strike out. Evidence – burden and standard of proof in civil cases – plaintiff must prove on balance of probabilities. Land law – proof of allocation/ownership of land must be established by credible, particularized evidence; general or ambiguous documents insufficient.
13 December 2018
Failure to consider mitigating factors and self-defence evidence justified reducing an eight-year manslaughter sentence to immediate release.
Criminal law – Manslaughter – Sentencing principles – requirement to consider mitigating factors individually; provocation and self-defence as mitigating circumstances; appellate interference where sentence is excessive.
13 December 2018
Court upheld ten-year manslaughter sentence despite trial judge’s generalized treatment of mitigating factors.
Criminal law – Manslaughter – sentencing – requirement that trial court expressly identify and consider mitigating factors and antecedents; guilty plea and remand time as mitigation; use of lethal weapon as aggravation; appellate interference standard.
12 December 2018
Appellant failed to prove BCG vaccination negligence or causation; appeal dismissed and retrial refused.
Medical negligence – causation – expert medical report indicating uncertain etiology of infection – hearsay evidence of defence medical officer – failure to prove negligence on balance of probabilities – refusal of trial de novo for afterthought failure to call witness.
12 December 2018
Unexplained delay in arrest undermines visual identification and supports appellant's alibi; convictions quashed.
Criminal law – Visual identification – Alibi – Unexplained delay in arrest – Prosecution must link identification to arrest; unexplained delay undermines reliability of identification; standard to interfere with concurrent findings of fact.
12 December 2018
Appeal allowed where trial judge ignored mitigating factors; sentence reduced to effect immediate release.
Criminal law - Sentencing - Appellate interference where trial judge acted on wrong principle or sentence manifestly excessive; mitigation - first offender status, guilty plea, time on remand; manslaughter.
12 December 2018
Failure to specify mitigation justified reducing a fifteen-year manslaughter sentence to eight years.
* Criminal law – Sentencing – Requirement for trial courts to specify which mitigating and aggravating factors were considered when imposing sentence – Generalised consideration insufficient. * Criminal law – Appellate review of sentence – Court may interfere where trial court acted on wrong principle or overlooked material factors. * Manslaughter – Sentence reduction where mitigating factors (guilty plea, pre-trial custody, dependants) were not expressly weighed.
12 December 2018
Appeal allowed and sentence reduced where trial judge failed to expressly weigh mitigating factors including plea, remorse and time served.
* Criminal law – Manslaughter – Plea of guilty – Acceptance of plea supported by post-mortem and statements. * Sentencing – Need for trial court to expressly consider mitigating factors (first offender, plea, remorse, time served, youth). * Appellate review – Interference where trial court overlooks material factors or imposes manifestly excessive sentence.
12 December 2018
Failure to invite objections to assessors and unsigned testimonies vitiated the trial; convictions quashed and retrial ordered.
* Criminal procedure – assessors – accused must be invited to state objections to proposed assessors before trial – failure vitiates trial. * Criminal procedure – recording of evidence – presiding Judge must authenticate testimony by signing – omission is incurable irregularity. * Criminal procedure – assessor absent for most of trial – an assessor who did not hear all evidence cannot give opinion; doing so renders trial nullity. * Retrial – application of Fatehali Manji principles – retrial ordered where trial was illegal or defective and interests of justice require it.
11 December 2018
The appellant's ten-year manslaughter sentence was upheld despite the trial Judge's generalized treatment of mitigating factors.
* Criminal law – Sentencing – Manslaughter – Requirement for trial Judge to expressly consider and record mitigating factors – appellate interference only where sentence is excessive in light of offence circumstances. * Use of lethal weapon and unlawful motive as significant aggravating features.
10 December 2018
A defective charge sheet citing wrong statutory provisions nullified convictions; appellate court quashed proceedings and ordered release.
* Criminal procedure – Framing of charge – Statement of offence must refer to the section creating the offence – Misdescription of statute in charge fatal.* Criminal law – Firearms offences – Wrong statutory reference in charge sheet vitiates proceedings.* Appellate jurisdiction – Revisional powers invoked to nullify proceedings where charge is incurably defective.* Retrial discretion – No retrial where defect is attributable to the prosecution.
10 December 2018
Failure to articulate mitigation was not fatal; ten-year manslaughter sentence upheld and appeal dismissed.
Criminal law – Sentencing after plea of guilty to manslaughter – Requirement to consider and state mitigating factors – Appellate interference where sentence is manifestly excessive – Use of excessive force as aggravating circumstance.
7 December 2018
Where ownership of land is disputed, civil determination must precede criminal prosecution for trespass or malicious damage.
Criminal law; trespass and malicious damage — disputed ownership of land — where ownership or boundary of private land is in dispute, the issue must be determined in civil proceedings before criminal prosecution for trespass/malicious damage can succeed; appellate review — reversal where second appellate court failed to recognise ownership dispute.
7 December 2018
Court upheld a ten-year manslaughter sentence despite the trial Judge’s inadequate recital of mitigating factors.
Criminal law – Manslaughter – Sentence – Mitigating factors (first offender, plea of guilty, lengthy remand) – Trial Judge’s duty to address mitigation – Appellate interference where sentence is manifestly excessive – Use of excessive force by person in authority as aggravating factor.
6 December 2018
Where ownership of land is disputed between the applicant and respondent, criminal prosecution must await civil determination.
Criminal law – Trespass and malicious damage – Where ownership or boundary of land is disputed, title must be determined in civil proceedings before criminal prosecution; conflicting testimony on ownership prevents criminal conviction; appellate correction where High Court failed to recognise need for civil determination.
6 December 2018
Appellate court affirms eight-year manslaughter sentence despite generalized mitigation consideration due to brutal, disproportionate attack.
* Criminal law – Sentencing – appellate intervention limited to wrong principle, overlooked material factors, or manifestly excessive sentence. * Sentencing – mitigating factors must be considered individually rather than generally. * Aggravating circumstances – viciousness of attack, use of a lethal weapon, and extent of injuries from post-mortem. * Manslaughter – plea of guilty and pre- and extra-judicial confessions relevant but do not preclude substantial sentence when force used is disproportionate.
6 December 2018
November 2018
A charge citing a non-existent provision denied the applicant a fair trial, warranting quashing of conviction and release.
Criminal law – charge sheet requirements – statement of offence must describe offence and cite correct provision (s.135 CPA) – defective citation of non-existent provision – incurable defect – unfair trial – nullity – Court of Appeal revisional powers (s.4(2) AJA) to quash conviction and set aside sentence.
30 November 2018
A charge sheet citing wrong statutory provisions is incurably defective and vitiates convictions; no retrial if prosecution's fault.
Criminal law – Charge sheet – Statement of offence must reference correct statutory section (s135(a)(ii)) – Misdescription of offence citing irrelevant provisions renders charge incurably defective – Proceedings and conviction vitiated – Revisional jurisdiction (s4(2) AJA) to nullify proceedings – No retrial where defect attributable to prosecution.
7 November 2018
October 2018
Survey-driven subdivision and allocation that disregard prior customary occupation without compensation are invalid; appeal dismissed.
Land law – customary occupation and title – validity of successive surveys and subdivision; reallocation of customary land without compensation void; limitation/adverse possession – requirement of uninterrupted possession for statutory period; non-joinder of land authority – not necessarily fatal to determination between present parties.
12 October 2018
The court upheld the respondent's customary title, found the subdivision and allocations illegal, and dismissed the appellant's appeal.
* Land law – customary occupation and right of occupancy – successive surveys and subdivisions – allocation of part of customary land without compensation invalid. * Civil procedure – non‑joinder of municipal authority – not fatal where rights between parties can be determined (Order I r.9 CPC). * Limitation – adverse possession requires uninterrupted statutory period; possession from 1996 did not reach twelve years when suit was filed.
12 October 2018
Registrar’s certificate valid once appellant is notified copies are ready; time to appeal runs from that notification, not physical collection.
Civil procedure — computation of time for appeal under Rule 90(1) — certificate of delay — effect of Registrar's notification that copies are ready for collection; time runs from appellant's awareness; Kantibhai Patel distinguished.
12 October 2018
Appeal dismissed for lack of a valid High Court certificate on points of law under section 47(2) LDCA.
Land disputes; Ward Tribunal-originated appeals; requirement for High Court Certificate under s.47(2) Land Disputes Courts Act; Appellate Jurisdiction Act s.5(2)(c) inapplicable; necessity for reasoned Ruling identifying certified point(s) of law; dismissal for lack of valid certificate.
11 October 2018
Waiting for certified court copies constitutes good cause for extension of time to file a revision application.
Civil procedure – extension of time (Rule 10 Court of Appeal Rules) – delay due to awaiting certified copies – Rule 65(4) sixty-day period for revision – service refused by respondent; refusal not a ground to delay hearing.
11 October 2018
Appellant failed to prove wrongful registration or pursue statutory indemnity; appeal dismissed with costs.
* Land law – title registration – extract from Land Register as conclusive evidence of title; evidential weight of registration. * Civil procedure – pre‑trial determinations – effect of predecessor judge’s ruling and limits on re‑deciding concluded issues by trial judge. * Statutory remedy – Land Registration Act s.100(1)–(6) – indemnity for loss from register errors must be sought from Registrar (s.100(6)) before court action. * Evidence – hearsay and conjecture cannot rebut documentary Land Register proof.
11 October 2018
Appeal dismissed: fraud allegation was a new matter; labour appeals limited to points of law and new issues not permitted.
* Labour law – execution of CMA consent decree – entitlement to repatriation, transport and daily subsistence allowances. * Set-off – unilateral deduction of alleged employee loan from terminal benefits without agreement or award. * Appealability – section 57 Labour Institutions Act: appeals to Court of Appeal from Labour Court limited to points of law. * Appellate principle – new matters not raised or decided below will not be entertained on appeal.
11 October 2018
A belated challenge to Ward Tribunal pecuniary jurisdiction, unsupported by valuation evidence, was an afterthought; appeal dismissed.
* Land law – Ward Tribunal pecuniary jurisdiction – statutory limit TZS 3,000,000 – necessity of evidence to establish value of land. * Civil procedure – jurisdictional challenge – may be raised at any stage but timing and proof are material; late objections after close of evidence may be treated as afterthoughts. * Limitation and possession – long, continuous occupation may extinguish rival title claims.
10 October 2018
Omission to record which member presided did not vitiate Ward Tribunal proceedings absent any failure of justice; appeal dismissed.
Land law – Ward Tribunal composition – omission to record presiding member – quorum compliance – procedural irregularity cured by absence of failure of justice under section 45 LDCA; Appeals – mandatory High Court certificate and conformity of grounds to certified points of law.
10 October 2018
Notice of appeal not struck out where Registrar-caused delay occurred and respondents later lodged the appeal.
Civil procedure — Strike out notice of appeal — Rule 89(2) — "essential steps" to pursue appeal — certified copy of High Court proceedings — Certificate of Delay — delay attributable to Registrar — application overtaken by events.
10 October 2018
An extension application must plead and prove good cause accounting for each day of delay; a jurat containing the attester’s name complies with section 8.
Civil procedure — Extension of time under Rule 10 — 'Good cause' required and must be proved; applicant must account for each day of delay; affidavit jurat must contain attesting officer's name per section 8 (Cap. 12) — unpleaded facts cannot be relied on orally at hearing.
9 October 2018
Use of a road reserve under statutory permit does not create an easement; malicious prosecution requires lack of probable cause and malice.
* Roads law – road reserve – statutory exclusivity of use under Roads Act s.29(1) – temporary private use by permit under s.29(2). * Property law – easement – an easement cannot be asserted over a road reserve protected for road use; adjoining landowner lacks standing to restrict licensed use. * Tort – malicious prosecution – ingredients: institution by defendant, absence of reasonable and probable cause, malice, and termination in plaintiff's favour; nolle prosequi not necessarily a favourable termination. * Civil procedure – appellate re-appraisal of evidence — Court of Appeal entitled to re-evaluate evidence subject to deference to trial court's advantage of witnessing witnesses.
9 October 2018
A direct 'second‑bite' leave application is premature if the applicant did not first obtain High Court extension of time.
* Appellate procedure – leave to appeal – Rule 45(b), Rule 47 & Rule 10 Court of Appeal Rules – requirement to first apply to the High Court for leave or extension of time before a 'second bite' application to the Court of Appeal.
8 October 2018
Omission of mandatory interlocutory proceedings and trial exhibits from the record renders an appeal incompetent and subject to striking out.
Civil Procedure – Appeals – Record of appeal – Mandatory inclusion of primary/core documents and interlocutory proceedings under Rule 96 – Omission of documents admitted at trial (including proof of locus standi) renders appeal incurably defective and incompetent; Preliminary objections – sufficiency of notice under Rule 107(1).
5 October 2018
Whether the respondent's land claim was time‑barred — court held accrual occurred in 2010; appeal dismissed.
Limitation of actions — Law of Limitation Act, item 22 and section 9(2) — accrual of right of action on dispossession/discontinuance; adverse possession vs invitee occupation; scope of appeal on certified points of law; pecuniary jurisdiction of Ward Tribunal not entertained on third appeal.
5 October 2018
Applicant granted fourteen days to file appeal documents after illness and good‑faith review efforts; respondents' affidavit struck out as defective.
* Civil procedure – extension of time/condonation – factors: length of delay, reasons (ill‑health), diligence, prejudice, point of law (illegality). * Affidavits – jurat/attestation – compliance with section 10 of the Oaths and Statutory Declarations Act; defective jurat renders affidavit fatally defective and liable to be struck out. * Labour law – appeals and leave to appeal – procedural compliance and timeliness. * Court discretion – review applications pursued in good faith may justify condonation of subsequent delay.
5 October 2018
Respondent’s land claim was not time-barred; accrual occurred on dispossession in 2010 under section 9(2).
* Land Law – limitation: 12-year limitation under Item 22, First Schedule to the Law of Limitation Act. * Limitation accrual – section 9(2): right accrues on dispossession or discontinuance of possession. * Adverse possession v. invitee occupancy – building and paying rent do not automatically establish title. * Concurrent findings of fact by trial and first appellate tribunals respected on third appeal. * Pecuniary jurisdiction determined from pleadings; burden to prove excess lies on alleging party.
4 October 2018
Respondent's land claim was within 12-year limitation; limitation accrued on dispossession in 2010, appeal dismissed.
Land law – limitation of actions – Item 22 Part I, First Schedule to the Law of Limitation Act – 12-year period to recover land; Accrual of right of action – section 9(2) (date of dispossession or discontinuance); Adverse possession – continuous occupation as invitee, building and payment of rent do not necessarily constitute dispossession; Civil procedure – pecuniary jurisdiction of Ward Tribunal – matter of pleadings and not a fresh point on second/third appeal.
4 October 2018
Appellant lacked statutory mining licence; disputed ridge lawfully allocated to respondent under SML 45/1999.
Mining law – Minerals vested in the State; mineral rights require statutory licences (Prospecting/Special/Primary) – possession or sub‑contracting and administrative promises do not confer mineral rights – interpretation and application of Special Mining Licence SML 45/1999 to determine lawful allocation.
3 October 2018
An appeal filed beyond the statutory sixty-day period, despite a delay certificate, is incompetent and struck out.
Limitation of appeals – Rule 90(1) Tanzania Court of Appeal Rules, 2009 – Registrar’s certificate of delay – exclusion of certified period from computation of time – effect of instituting appeal out of time – incompetence and striking out of appeal – exercise of revisionary powers under s.4(2) Appellate Jurisdiction Act – inability to make substantive/consequential orders where appeal is incompetent.
3 October 2018
The appellant's appeal was struck out as time‑barred; no consequential orders or costs were made.
Appeal — time limits — Rule 90(1) Court of Appeal Rules — registrar’s certificate of delay — competence of appeal — striking out time‑barred appeals — exercise of revisionary powers under s.4(2) Appellate Jurisdiction Act — consequential orders and costs where time issue raised suo motu.
3 October 2018
Application for extension of time denied: delay inadequately explained and alleged illegality not particularized.
* Civil procedure — extension of time under Court of Appeal Rules, Rule 10 — requirement to show good cause; factors: length of delay, reasons, diligence, prejudice, and point of law (illegality) apparent on record. * Applicants must account for each day of delay; ignorance of law or lack of counsel is not good cause. * General, unparticularized allegation of illegality is insufficient to found extension of time.
3 October 2018
Appeals from the Labour Court require no leave but must be confined to points of law under section 57 LIA.
Labour Court appeals – s.57 Labour Institutions Act – right to appeal on point of law only; appeals from Labour Court do not require leave under s.5(1)(c) AJA even if proceedings arose under CPC; factual grounds incompetent; revisional jurisdiction cannot cure factual grounds.
3 October 2018
Failure to hear an affected party in judicial review vitiates the decision and requires remittal for a fresh hearing.
Administrative law – Judicial review – Failure to implead or hear an affected party breaches audi alteram partem and Article 13(6)(a) – Decision made without hearing is nullity – Remittal for fresh hearing; Labour law – procedural fairness in review of ministerial labour decisions.
2 October 2018
September 2018
Failure to state reasons for transfer of a partly heard trial under section 299(1) CPA vitiates the subsequent proceedings.
* Criminal procedure – Succession of judge – Section 299(1) Criminal Procedure Act – Requirement to state and record reason for transfer of a partly heard trial. * Jurisdiction – Failure to state cause for transfer – Successor judge lacks jurisdiction; proceedings vitiated. * Remedy – Nullification of irregular proceedings, quashing of conviction and sentence, remittal for retrial before another judge with original assessors or de novo. * Right of accused – Entitlement to be informed of right to resummon witnesses under s.299(1).
28 September 2018