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.
69 judgments

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69 judgments
Citation
Judgment date
December 2021
Breach of mortgagee's duty to obtain best price does not automatically discharge mortgagor from outstanding loan; deficiency remains recoverable.
* Land law – Mortgagee’s duty of care – s.133 Land Act – duty to obtain best price reasonably obtainable and rebuttable presumption where sale ≥25% below comparable prices. * Remedies for breach – nullification of sale or damages; breach does not automatically discharge mortgagor from outstanding debt. * Right of mortgagee to pursue deficiency after sale.
21 December 2021
Provocation and alleged witchcraft were not proved; evidence showed premeditated murder, so conviction and death sentence affirmed.
Criminal law – Murder v. Manslaughter – Provocation (ss. 201–202 Penal Code) – Heat of passion and objective test; witchcraft allegations – requirement of sudden shock and physical evidence; premeditation and malice aforethought established by conduct (luring, arson, delay, fatal machete attacks) – conviction and death sentence upheld.
7 December 2021
Holder of a mining licence failed to prove land description or trespass; appeal dismissed with costs.
* Land law – Special mining licence – claim of trespass by licence holder – requirement to prove demarcation and boundaries of suit land; * Evidence – burden of proof in civil claims – 'he who alleges must prove' and weight of concurrent findings; * Possession and trespass – occupier's possession is central; claimant must establish encroachment; * Civil procedure – compensation awarded without being pleaded may be quashed.
3 December 2021
Failure to administer oath and to sign witnesses' evidence vitiated CMA and High Court proceedings; matter remitted for de novo hearing.
* Labour law – arbitration – mandatory administration of oath or affirmation to witnesses under Mediation and Arbitration Rules and Oaths Act – omission vitiates proceedings. * Evidence – presiding officer’s signature on recorded witness evidence – authenticity and veracity – omission a fatal irregularity. * Civil procedure analogies – Order XVIII Rule 5 CPC and precedents applied to arbitration proceedings. * Remedy – nullification of proceedings, quashing of award and judgment, remittal for de novo hearing; costs each party.
3 December 2021
Conviction quashed where victim's testimony conflicted with medical evidence and voire dire was defective.
Criminal law — Evidence — Sexual offences: victim's evidence and medical testimony irreconcilable; defective voire dire under s.127(2) renders child evidence unsworn; corroboration and credibility; misapprehension of evidence justifies disturbing concurrent findings.
3 December 2021
Trial judge’s summing-up comments that influenced assessors vitiated the trial, quashing conviction and ordering retrial.
Criminal procedure — Assessors — Trial Judge must not disclose views or influence assessors when summing-up — Where a Judge departs from assessors' unanimous opinion, reasons should be given — Improper summing-up vitiates proceedings and warrants retrial.
3 December 2021
Court upheld conviction for unnatural offence despite expungement of child's testimony and medical report, relying on credible circumstantial evidence.
Criminal law – Unnatural offence (sodomy) – Penetration proof – child witness evidence – section 127(2) Evidence Act (promise to tell truth) required and failure to record it renders testimony inadmissible – medical report must be read and explained before admission – delay in arraignment under section 32(1) CPA may be irregular but not necessarily fatal – right to legal representation not automatic; apply for legal aid – credible eyewitness and medical oral evidence can sustain conviction circumstantially.
3 December 2021
Acceptance of compensation and failure to use statutory remedy estop a former owner from reclaiming title; appeal dismissed with costs.
Acquisition of property – effect of acquisition under Acquisition of Buildings Act 1971 – vesting in Registrar; Compensation – acceptance, mode and effect; Estoppel/election – accepting compensation and paying rent bars later claim to title; Statutory remedy – Appeals Tribunal for disputes on compensation and failure to invoke it; Pleadings – constitutional challenge must be pleaded; Evidence – proper evaluation by trial court.
3 December 2021
Omission to sign witness testimony rendered evidence unauthentic; conviction quashed and appellant released.
* Criminal procedure – Evidence authenticity – Requirement under section 210(1)(a) CPA that trial Judge sign record after each witness’s testimony – omission vitiates evidence. * Applicability – Section 210(1)(a) CPA applies to High Court trials. * Remedies – Use of revisional powers under section 4(2) AJA to nullify proceedings, quash conviction and set aside sentence; retrial only where interests of justice require (Fatehali Manji).
2 December 2021
Credible complainant testimony can prove rape despite an unread medical report; PF3 expunged and appeal dismissed.
* Criminal law – Sexual offences: rape – conviction may rest on credible victim’s testimony even without medical corroboration. * Evidence – medical report (PF3) admitted but not read out: exhibit expunged; medical evidence corroborative not mandatory. * Evidence – competence and credibility of elderly complainant: no special warning or corroboration required if testimony is consistent. * Legal aid – entitlement not automatic; accused must claim indigence/apply to certifying authority. * Appellate jurisdiction – Court will not entertain new factual grounds not raised and decided below. * Criminal procedure – alibi raised without prior notice may be disregarded.
2 December 2021
Omission of judge's signatures on witness evidence rendered the conviction unsafe; conviction quashed and no retrial ordered.
Appellate procedure — Trial judge's signatures on witness statements — Absence renders recorded evidence suspect; Evidence — identification and chain of custody of exhibit (mobile phone) — serial number, markings and retrieval contradictions; Remedy — revisional quashing of conviction and refusal to order retrial where prosecution case is materially deficient.
2 December 2021
Omission of the trial magistrate's required signatures rendered the proceedings a nullity; conviction quashed and retrial ordered.
* Criminal procedure – recording of evidence – requirement that magistrate append signature after recording each witness’s evidence – section 210(1)(a) CPA; * Procedural irregularity – omission to sign renders proceedings unauthentic and a nullity; * Appellate jurisdiction – power under section 4(2) AJA to nullify proceedings, quash conviction and set aside sentence; * Retrial – principles governing ordering of retrial (Fatehali Manji) and assessment of whether prosecution evidence is sufficiently strong or susceptible to cure on retrial.
2 December 2021
Omission of the trial judge’s signature on each witness’s testimony vitiates proceedings and warrants nullification and retrial.
Civil procedure — Evidence — Mandatory requirement for judge’s signature at end of each witness’s testimony (Order XVIII r.5 CPC; s.210 CPA) — Omission vitiates proceedings — Authenticity and veracity of court record — Revisional powers (s.4(2) AJA) — Nullification, quashment and remittal for retrial.
1 December 2021
A judge's decision on a suo motu legal issue without hearing parties violates the right to be heard and vitiates the judgment.
Criminal procedure — audi alteram partem — judge raising legal issue suo motu during judgment composition without hearing parties — violation of right to be heard renders judgment nullity — remedy: quash, set aside orders and remit for rehearing by another judge; bail pending appeal not available where notice of appeal has ceased.
1 December 2021
High Court’s suo motu legal finding without hearing parties vitiated its judgment; appeal remitted and appellant remitted to custody.
Criminal law – forgery; Procedural fairness – right to be heard (audi alteram partem); Appellate procedure – raising legal issues suo motu; Remedy – nullification and remittal; Bail pending appeal – jurisdiction where notice of appeal has ceased.
1 December 2021
Deferring reasons for trials-within-trial and delivering them before assessors prejudiced appellants; retrial ordered.
* Criminal procedure – trial within a trial – admissibility of cautioned statements – requirement that assessors retire and ruling be given before main trial proceeds; * Procedural irregularity – deferral of reasons and delivering them in assessors’ presence – potential prejudice to defence and prosecution; * Revisional powers – nullification of proceedings, quashing convictions and ordering retrial.
1 December 2021
November 2021
Extension of time refused where alleged illegality was not apparent and the application was an abuse of process.
Civil procedure – extension of time – illegality may constitute sufficient cause but must be apparent on the face of the record and of sufficient importance; repetitive applications – abuse of court process – dismissal with costs; authorities: Principal Secretary v Devram Valambia; Lyamuya Construction Co. Ltd.
29 November 2021
Applicant failed to show good cause for extension of time; unexplained delays and lack of diligence led to dismissal with costs.
Extension of time – Rules 10 and 90(1) – requirement to account for each day of delay – diligence v. sloppiness – ignorance of law or lack of guidance not good cause – relevant authorities: Lyamuya, Bushiri, Airtel, Farida F. Mbarak, Laureno Mseya.
26 November 2021
August 2021
Voire dire, proof of penetration corroborated by medical and maternal evidence; defective charge curable and appeal dismissed.
* Evidence — Child witness — Voire dire under s.127 Evidence Act — recording opinion that child understands duty to tell truth. * Criminal law — Rape — Proof of penetration — Victim's unsworn testimony corroborated by maternal observation and medical findings; penetration however slight sufficient. * Procedure — Defective citation in charge curable under s.388 Criminal Procedure Act when particulars prevent prejudice. * Appeals — Second appeal cannot raise matters not argued in first appeal.
4 August 2021
July 2021
Whether summary dismissal was mandatory and whether the Minister's lesser penalty was unreasonable under the SEA.
Administrative law – judicial review – unreasonableness/Wednesbury standard; Labour law – disciplinary penalties under the Security of Employment Act (s.21: penalties and s.21(2) lesser penalty for first breach); Ministerial discretion on references (s.27(2)); prerogative remedies – certiorari and mandamus; effect of certiorari on underlying Board decisions.
28 July 2021
Legal title registered in appellant held in trust for unincorporated association; respondent entitled to beneficial ownership.
Unincorporated association — capacity to hold property — registered title held by third party as trustee — oral agreement and conduct giving rise to trust — beneficial ownership v. legal title — re-appraisal of evidence by Court of Appeal.
27 July 2021
Statutory notice and auction complied with mortgage law; sale upheld and appeal dismissed with costs.
Mortgage law — Notice of default — Service and compliance with Mortgage Deed and s.127 Land Act (as amended) — Mortgagee’s power of sale under ss.126,132 Land Act — Auction procedure and Auctioneers Act compliance — Effect of Mortgage Financing Act (2008) reducing notice to 60 days — Duty to obtain best price and s.133 Land Act — Application of proceeds and refund under s.137 Land Act — Bona fide purchaser protection.
23 July 2021
Applicant failed to show due diligence or necessity to admit additional survey map or a locus visit on appeal.
Civil procedure — Admission of fresh evidence on appeal — Ladd v Marshall test — reasonable diligence, probable influence, credibility; locus in quo visits; redundancy of evidence; abuse of process.
16 July 2021
Court ordered tracing and reconstruction of missing appeal record rather than immediate quash and release where notice was defective.
Criminal appeal — Missing record of proceedings — Registrar's duty under Rules 68 and 71 — Prisoner lodging of notice (Rule 75) — Validity of undated/unendorsed notice of appeal — Reconstruction of missing record and required cooperation of registries, trial/appellate courts, prosecution, police and prisons.
16 July 2021
Revision dismissed: failure to lodge/annex notice of appeal and impugned decision rendered the certificate application incompetent.
* Land appeals (Ward Tribunal origin) – requirement of High Court certificate on point of law (s.47(3), (4) Land Disputes Courts Act). * Court of Appeal Rules – Rule 46(1), Rule 47(1), Rule 49(3), Rule 84(1): notice of appeal must be lodged prior to application for certificate; copies of notice and impugned decision must be annexed; service requirements. * Procedural competence – failure to annex required documents and to show service is fatal; striking out appropriate remedy. * Prematurity – unsuccessful or struck-out High Court applications must be corrected/refiled before invoking Court of Appeal revisional jurisdiction.
15 July 2021
Conviction based solely on improperly recorded, uncorroborated extra-judicial statements is unsafe and was quashed.
Criminal law – Extra-judicial statements recorded by a Justice of the Peace – Compliance with Chief Justice’s Guide – Voluntariness and admissibility; Corroboration requirement – Conviction unsafe where based solely on uncorroborated, improperly recorded confessions; Insufficient circumstantial evidence cannot sustain conviction once confessions are discounted.
15 July 2021
Applicant failed to prove the appeal was withdrawn by fraud or mistake; restoration denied and application dismissed.
Criminal procedure – restoration of withdrawn appeal under rule 77(3) – requirements: withdrawal induced by fraud or mistake and interests of justice; Evidence – burden on applicant to prove withdrawal by fraud or mistake with supporting evidence; Procedural relief – consequential orders dependent on successful restoration of appeal.
15 July 2021
Night-time visual identification by moonlight was unsafe; convictions quashed and appellants released.
Criminal law – Robbery with violence – Visual identification at night by moonlight; reliability and Waziri Amani factors; single-witness evidence; need for corroboration; adverse inference for omission to call available witnesses; failure to connect arrests to charged offence.
14 July 2021
Failure to serve the written request for certified High Court proceedings invalidated the certificate of delay; appeal was time-barred and struck out.
Civil procedure – Appeals – Time limit for instituting appeal – Rule 90(1) & (3) Tanzania Court of Appeal Rules – Certificate of delay; requirement that application for certified proceedings be in writing and served on respondents – Failure to serve invalidates certificate – Jurisdictional nature of sixty-day rule – Overriding objective cannot cure mandatory procedural defects.
14 July 2021
A court’s suo motu decision on limitation without hearing parties violates the right to be heard and renders the judgment null.
* Civil procedure – right to be heard (audi alteram partem) – court raising and deciding limitation suo motu while composing judgment without affording parties opportunity to address – such judgment a nullity. * Constitutional law – natural justice – right to be fully heard as fundamental right. * Appellate jurisdiction – revisional powers – nullification and remittal for rehearing.
14 July 2021
Victim’s credible evidence and medical corroboration upheld rape conviction; charge‑sheet defect cured and appeal dismissed.
* Criminal law – Rape of a child – Evidence of victim under age eight – penetration and identification as primary proof. * Criminal procedure – Defective charge sheet – omission of statutory subsection curable under s.388 CPA where particulars give sufficient notice. * Appeals – Second appeal jurisdiction – new grounds not raised in first appeal are inadmissible. * Evidence – Corroboration and medical examination as supporting proof; alibi failing to discharge burden.
14 July 2021
Court dismissed appeal, holding child’s sworn testimony and mother’s independent inspection sufficed for conviction.
* Criminal law – Evidence of child witness – Voire dire: once a child understands oath and duty to speak truth, no separate intelligibility test required. * Evidence – Child witness credibility – Unsuspended credible child testimony may suffice for conviction under section 127. * Evidence – Parent's non‑expert inspection – A parent may give eyewitness evidence of physical signs without being an expert and can corroborate a child witness. * Criminal procedure – Alibi – Where prosecution establishes accused's presence, unsupported alibi is insufficient. * Appellate procedure – New factual grounds not raised below are not entertainable by the Court of Appeal.
13 July 2021
Trial nullified for inadequate summing up on malice aforethought and alibi; retrial ordered.
* Criminal procedure – Duty to authenticate witness testimony – presiding judge must append signature at end of a witness's testimony (after all stages of examination and any judicial/assessor questions). * Criminal procedure – Trials with assessors – mandatory duty to sum up and explain vital points of law to assessors, including malice aforethought and alibi; failure renders trial unfair and a nullity. * Remedy – retrial before a new judge and different assessors.
13 July 2021
Eyewitness identification in daylight and hot pursuit can sustain armed robbery convictions despite non-production of stolen items.
Criminal law – armed robbery – identification in daylight and hot pursuit; Evidence Act s.143 – prosecution discretion on witnesses; non-production of stolen property goes to weight not admissibility; cautioned statements recorded outside statutory period expunged.
8 July 2021
Visual and voice identification, supported by medical and circumstantial evidence, upheld murder convictions and death sentences.
Criminal law – visual identification – application of Waziri Amani safeguards; voice identification – approached with caution but admissible if witness familiar; autopsy report not indispensable where medical and eyewitness evidence prove death and cause; alibi – burden to prove; malice aforethought – established by brutal, premeditated attack (matricide).
8 July 2021
The Tax Appeals Board has exclusive jurisdiction over civil disputes arising from administration of revenue laws, including damages claims.
Tax Revenue Appeals Act s.7 – Board’s sole original jurisdiction over civil proceedings arising from revenue laws; s.7A and s.12 – procedural requirements for tax assessments, not limits on jurisdiction; inclusion of Cap.124 in TRA Act First Schedule; jurisdictional ouster of ordinary courts for revenue-law disputes; relief sought does not determine forum.
5 July 2021
Whether service irregularity and a wrongly dated decree warrant striking out an appeal or allow rectification by supplementary record.
* Civil procedure — Preliminary objection — requirement that a preliminary objection raise a pure point of law — factual disputes on service require evidence and cannot be disposed of on objection. * Court of Appeal Rules, r.97(1) — duty to serve memorandum and record of appeal within seven days where respondent has given address for service. * Decree — must bear date of pronouncement of judgment; discrepancy renders decree defective (Order XXXIX r.35(1) CPC). * Overriding Objective (ss.3A–3B AJA) and r.96(7) — Court may allow supplementary record to cure defects rather than striking out appeal.
5 July 2021
The Court affirmed an eight-year sentence for attempted murder, finding mitigating factors were considered and the term was not excessive.
* Criminal law – Attempted murder – sentence – whether eight years imprisonment excessive; consideration of mitigating factors (first offender, youth, guilty plea, time in custody); appellate interference with sentence limited to specific grounds.
5 July 2021
May 2021
Appeal struck out as time‑barred because the Certificate of Delay was defective and not amenable to cure absent an application.
Civil procedure – Appeals – Certificate of Delay under Rule 90(1) – requirement to refer to the decision appealed against and to accurately certify excluded period – defective certificate renders appeal time‑barred; overriding objective cannot cure defects where no application for rectification is made; court cannot grant unprayed relief.
7 May 2021
Review application dismissed; alleged manifest error and date/cost discrepancies are either non-reviewable or clerical and correctable.
* Appellate procedure – Review – scope limited and sparingly exercised; cannot be used to re-argue appeal; Rule 66(1).; * Evidence – factual re‑evaluation not permitted on review; review only for manifest error on face of record.; * Civil procedure – Judgment v. extracted Order discrepancies; practice on dating judgments and Registrar's delivery entries.; * Court rules – clerical/arithmetical mistakes correctable under Rule 42(1) of the Court of Appeal Rules.; * Public policy – finality of litigation.
7 May 2021
A defective certificate of delay may render an appeal time-barred, but court can allow rectification under the overriding objective.
* Civil procedure – Certificate of delay – Rule 90(1) and Form L – requirement to state aggregate days excluded and proper start/end dates. * Time limitation – defective certificate of delay normally renders appeal time-barred. * Overriding objective (s.3A AJA and Rule 2) – court may permit rectification of defective certificate to advance substantive justice.
7 May 2021
High Court lacked power to revise pre-committal proceedings or order bail/dismissal for unbailable terrorism offences.
Criminal procedure — High Court revision — limits under ss.372 & 373 CPA; pre-committal matters not revisable; Bail — offences under Prevention of Terrorism Act are unbailable per s.148(5)(a)(iv) CPA; subordinate/committal courts lack jurisdiction to grant bail or dismiss charges triable only by the High Court.
7 May 2021
A High Court ruling granting relief not sought by the applicant was set aside and remitted for fresh determination.
Revision; High Court granted relief not prayed for; slip rule (clerical correction) inapplicable to substantive misdirection; revisional powers under s.4(3) AJA; respondent without affidavit limited to points of law.
7 May 2021
Prosecution under a repealed statute vitiates proceedings; convictions are quashed and release, not retrial, may be ordered.
Criminal law — Repeal of statute — Charging under repealed law — Effect of repeal: obliteration absent savings — Proceedings founded on repealed statute are nullities — Appellate jurisdiction s.4(2): quashing null proceedings — Retrial vs release where appellant served substantial time under illegal conviction.
6 May 2021
Documents admitted at preliminary hearing did not vitiate trial; provocation and intoxication failed to reduce murder to manslaughter.
Criminal procedure – preliminary hearing under s.192 CPA – documents admitted deemed proved; assessors’ rights – summing up sufficient to explain admitted statements; substantive law – provocation and intoxication defences; malice aforethought established by weapon, wounds and conduct; murder upheld.
5 May 2021
Conviction for armed robbery quashed after confessions were improperly admitted and evidence of theft was insufficient.
Criminal law – Armed robbery – Admissibility of cautioned and extra-judicial statements – Voluntariness inquiry required before admission where objection is raised – Retracted confessions have little evidentiary weight – Corroboration of co-accused confession (s.33(2) Evidence Act) – Proof of theft and ownership essential to convict for armed robbery.
5 May 2021
Consent decree on mortgage sale bars subsequent suit; auction/execution irregularities must be raised in execution proceedings.
* Civil procedure – Res judicata – applicability of section 9 CPC – consent/compromise decree registered as court decree operates conclusively; parties and privies. * Execution law – sale under decree – alleged irregularities/fraud to be challenged by execution application (Order XXI Rule 88(1)/section 38(1) CPC), not by separate suit. * Agency and privity – auctioneer as agent and purchaser acquiring interest become privies for res judicata purposes.
3 May 2021
A defective Certificate of Delay may be cured by leave to obtain a proper certificate under the overriding objective.
Certificate of delay – defect or wrong reference – whether defect vitiates exclusion of time under rule 90(1); overriding objective (sections 3A & 3B AJA and Rule 2) – leave to obtain/rectify certificate – conflicting precedents; appellate procedure.
3 May 2021
Victim’s credible identification and medical evidence proved statutory rape; cautioned statement expunged but conviction upheld.
Criminal law – Rape (statutory) – proof of penetration and age; Visual identification – Waziri Amani factors; New grounds on second appeal – jurisdictional limits; Admissibility – cautioned statement must be read over in court; Medical evidence – clinical officer with diploma competent to examine and prepare PF3.
3 May 2021
April 2021
Failure to properly involve assessors, unsigned proceedings and deficient summing-up vitiated the trial and warranted retrial.
Criminal procedure – Assessors: statutory selection/introduction duties (ss. 265, 283, 285 CPA) – Judge’s failure to inform accused of right to object – Judge’s signature on recorded evidence – insufficiency of summing up to assessors – incurable procedural irregularities – retrial ordered.
30 April 2021