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.
91 judgments

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91 judgments
Citation
Judgment date
December 2023
Failure to prove authorship of disputed loan documents and improper burden shifting led to quashing of the judgment.
* Evidence Act s.110 – burden of proof – plaintiff who alleges loan must prove authenticity of documentary evidence. * Civil Procedure Code Order VI r.4 – fraud/forgery must be particularized in pleadings. * Standard of proof – allegations of fraud/forgery require a higher degree than ordinary balance of probabilities. * Documentary evidence – weight and authorship; necessity to call bank/technical witnesses to establish cheque authenticity. * Civil appeal – improper shift of burden and judgment against the evidence justify quashing decree.
21 December 2023
A three‑year unexplained delay in serving notice of appeal is inordinate; applicant failed to show good cause for extension.
* Civil procedure – extension of time – requirements for showing good cause – factors: length of delay, reasons, diligence, prejudice, point of law (Lyamuya, Devram, Bushiri). * Delay of over three years without adequate explanation or accounting is inordinate and may justify refusal to extend time. * Applicant must account for each day of delay and demonstrate prompt action upon discovery of omission.
14 December 2023
Court upheld statutory rape conviction: victim credible, age and penetration proved; appeal dismissed.
* Criminal law – Statutory rape – proof of age and penetration – victim’s testimony as best evidence; PF3 and school register as evidence of age. * Criminal procedure – Preliminary hearing under s.192 Criminal Procedure Act – proper conduct and purpose. * Criminal procedure – Succession of magistrates – s.214 compliance and absence of miscarriage of justice. * Evidence – Credibility and corroboration in sexual offence cases.
14 December 2023
A fixed‑term appointment supplants a prior unspecified‑term employment; oral promise to revive it is inadmissible against the written contract.
* Labour law – fixed‑term appointment v. unspecified (permanent) contract – whether fixed‑term appointment terminates prior permanent contract automatically. * Employment contracts – possibility of concurrent full‑time contracts – impracticability; part‑time exception distinguished. * Evidence – parol evidence rule (s.100 & s.101 Evidence Act) and s.14(2) ELRA – oral agreement cannot vary written employment contract unless exception applies. * Procedural – res judicata issue raised but not dispositive once primary contractual issues resolved.
14 December 2023
Extension of time to file revision granted where delay was promptly explained and alleged denial of hearing constituted good cause.
* Civil procedure — Extension of time under Rule 10 — good cause requirement — factors: length of delay, reasons for delay, prejudice. * Extension of time — illegality of impugned decision — denial of right to be heard may constitute good cause if apparent on face of record. * Probate/procedure — locus/standing — party appearing via suo motu district court review may properly appeal to High Court.
14 December 2023
Failure to read prosecution documents under s.246(2) CPA invalidates committal and quashes convictions.
Criminal procedure — Committal proceedings — Section 246(2) Criminal Procedure Act — Subordinate court must read or cause to be read information and prosecution documents — Mere listing of documents insufficient — Non‑compliance vitiates committal and subsequent trial; remedy: nullification, quashing of conviction and remittal for fresh committal.
14 December 2023
Review application dismissed: alleged bias, denial of hearing and manifest error not established; review cannot substitute an appeal.
Review jurisdiction — Rule 66(1) AJA/Rules — only for manifest error on face of record or deprivation of right to be heard; bias and bench composition — complaint must be timely and supported; re‑litigation via review not permitted; unincorporated association and property ownership considered in appellate evaluation of evidence.
14 December 2023
Review application dismissed: "permissible penalty" is not mandatory summary dismissal; no manifest error on the record.
* Appellate procedure – Review of Court of Appeal judgment – Rule 66(1)(a): manifest error on the face of the record causing miscarriage of justice required. * Employment law – 2nd Schedule, Security of Employment Act – "permissible penalty" construed as maximum allowable, not mandatory summary dismissal. * Civil procedure – Abuse of process – review cannot be used to re-open or rehear matters already decided on appeal.
14 December 2023
Court held respondent was a party and attachments of his personal property were wrongful; appeal dismissed.
* Civil procedure – party status and representation – village chairman sued in representative capacity; failure to object waives misjoinder. * Execution law – attachment and sale – wrongful attachment of personal property where proceedings involved village representation. * Remedies – objection proceedings under Order XXI, r.57 not decisive where party status and wrongful attachment established. * Appellate review – High Court's quashing of DLHT order and restoration/compensation upheld.
14 December 2023
Applicant failed to account for delay or show an arguable ground; extension of time to file review denied.
Criminal procedure — Extension of time under Rule 10 — Applicant must account for each day of delay and show good cause — Requirement to disclose an arguable ground under Rule 66(1) (e.g., manifest error on face of record) — Discretion guided by length of delay, reasons, prejudice, diligence and point of law.
14 December 2023
Applicant's failure to account for delay justified refusal to extend time; one assessor's absence did not vitiate DLHT proceedings.
Civil procedure – extension of time – applicant must account for each day of delay; Illegality – limited to jurisdictional or material procedural defects; Land Disputes – DLHT may continue with chairman and one assessor under s.23(3).
13 December 2023
Appeal dismissed: prosecution proved statutory rape; new factual grounds at second appeal were not entertained.
Criminal law - Statutory rape (s.130(2)(e)) - Proof of age and penetration - Corroboration by parent and medical evidence (PF3) - Identification - Appellate procedure - New grounds not raised in earlier appeal not entertained.
13 December 2023
A child witness must make an express promise to tell the truth; absence invalidates her testimony and quashes the appellant's conviction.
* Criminal law – Sexual offences – Rape – Necessity of reliable evidence from child complainant; statutory promise under section 127(2) Evidence Act required when child testifies without oath. * Evidence law – Witness of tender age – requirement of an express promise to tell the truth and not lies; failure to comply renders testimony of no evidential value. * Evidential sufficiency – Hearsay – testimony by a parent recounting a child’s statements cannot by itself corroborate the child once the child’s testimony is expunged. * Sentence – enhancement to life reversed as conviction quashed.
13 December 2023
Oral confessions made under restraint and before a crowd were not voluntary and required corroboration; convictions quashed.
* Evidence — Confessions — Oral confessions made in presence of vigilantes and a crowd — voluntariness and free agent requirement — need for corroboration. * Evidence — Failure to tender cautioned/extrajudicial statements — adverse inference. * Criminal appeal — Grounds alleging last-seen/circumstantial reliance misconceived where trial court did not rely on them.
12 December 2023
November 2023
Review dismissed: applicants not deprived of hearing, typographical error corrected, fraud not shown; each party to bear own costs.
Court of Appeal — Review — Limited to manifest errors on face of record, deprivation of hearing or fraud; cannot be used to re‑argue merits or probe prior proceedings; oral/unopposed applications in court proceedings permissible under procedural rules; clerical errors correctable.
14 November 2023
General delay allegation insufficient; respondent’s timely applications and reminders to Registrar constituted essential steps, application dismissed.
- Civil procedure – Court of Appeal Rules, 2009 – Rule 89(2): strike out notice of appeal for failure to take essential steps; - Court of Appeal Rules – Rule 90: time to institute appeal, certificate of delay and obligations when Registrar fails to supply records; - Pleadings principle – parties bound by their pleadings; submissions cannot introduce new factual allegations; - Follow‑up diligence – applying for records and sending reminders may constitute essential steps to prosecute appeal.
13 November 2023
Review refused: review cannot be used to re-open factual findings or re-appraise reasoning; dismissal with costs.
* Appellate review — scope of review under section 4(4) AJA and rule 66 — limited to apparent errors on the face of the record. * Concurrent findings of fact — appellate restraint on re-opening factual determinations in second appeals. * Review vs appeal — re-appraisal of evidence and reasoning is not a ground for review. * Contract law — sanctity of contract and judicial reduction of exorbitant contractual interest (from 30% to 5%).
10 November 2023
The applicant's long unexplained delay and failure to state proposed review grounds led to dismissal of the extension application.
* Criminal procedure – extension of time to apply for review – applicant must show good cause and indicate proposed grounds under rule 66(1). * Delay – inordinate and unexplained delay is fatal; applicant must account for the period. * Ignorance of law or custodial status does not excuse procedural non-compliance. * Court not obliged to inform parties of right to review. * Discretionary exercise guided by length of delay, reasons, prospects of success and prejudice.
9 November 2023
Court granted conditional stay pending appeal where applicants showed likely substantial loss and undertook acceptable security.
Civil procedure – Stay of execution pending appeal; Rule 11(5) Court of Appeal Rules, 2009 – requirements of substantial loss and firm undertaking to furnish security; security must not be part of decreed subject land.
9 November 2023
Non-joinder of a titled purchaser denied the right to be heard and vitiated the High Court's decision, warranting re-hearing.
Land law; non-joinder and right to be heard – Order I r.10(2) CPC; certificate of title as prima facie proof of legal interest; revisional powers under AJA; vitiation of proceedings by denial of audi alteram partem.
9 November 2023
An appointed administrator has locus to be joined in place of a deceased party if records show lawful appointment and identity.
Civil procedure – substitution of parties on death – Rule 57(3)-(5) Court of Appeal Rules – administrator’s locus standi to be joined within twelve months; identity/alias issues in letters of administration; lower court/registrar decisions cannot vary Court of Appeal determinations.
8 November 2023
Notice of appeal struck out for failure to take essential steps and collect the record under Court of Appeal Rules.
Civil procedure — Appeal — Striking out notice of appeal for failure to take essential steps to prosecute — Court of Appeal Rules, 2009: rule 89(2) and rule 90(5) — duty to collect records and follow up registrar's notification.
7 November 2023
Review dismissed where alleged fraud/perjury was not raised or decided below; review jurisdiction is narrowly confined.
Practice and procedure – Review jurisdiction of Court of Appeal – narrow and exceptional remedy; issues must arise from pleadings; appellate court will not determine allegations of fraud or perjury not raised or decided in lower courts; affidavit evidence tied to withdrawn/struck-out proceedings is not available to support review.
7 November 2023
Court refused extension to seek revision against High Court's non-appealable refusal to certify a point of law.
* Appellate Jurisdiction Act s.5(2)(c) – certificate on point of law – exclusive jurisdiction of the High Court; refusal final and not appealable. * Civil Procedure – Rule 10 Court of Appeal Rules – extension of time – cannot be used to pursue statutorily barred remedies; exercise in futility. * Revision jurisdiction – Court of Appeal cannot compel High Court to issue certificate or certify points of law itself.
7 November 2023
Prior spousal consent to one mortgage does not validate a later mortgage; bona fide purchaser's title is protected.
Land law – mortgage of matrimonial home – spousal consent required for each mortgage (s.114 Land Act; s.59 Law of Marriage Act) – prior consent to an earlier facility does not validate a later separate mortgage; Civil procedure – certificate of delay and time for appeal – validity of certificate where complete record delayed; Property law – bona fide purchaser for value without notice protected (s.135 Land Act); Remedy – damages for unauthorized or irregular exercise of power of sale (s.134(4) Land Act).
7 November 2023
Failure to serve the Rule 90(3) letter invalidated the delay certificate and rendered the appeal time-barred.
* Civil procedure – Appeal competency – Service of written request for copies of High Court proceedings – Rule 90(3) Court of Appeal Rules – certificate of delay – where no acknowledgement or affidavit proving service, certificate invalid and appeal time-barred.
6 November 2023
October 2023
Nighttime identification and non-compliant cautioned statements were unsafe; convictions quashed and sentences set aside.
* Criminal law – Identification evidence – Night-time visual identification – need for clear evidence of light source, intensity and duration to avoid mistaken identity. * Criminal procedure – Cautioned statements – compliance with section 50 (four-hour rule), section 51 (extension/exclusion of time), section 57 (recording and certification duties) and section 58 of the CPA – non-compliance vitiates statements. * Appeal – Appellate re-evaluation of credibility and consistency where sole identification and confessions are central.
25 October 2023
Thirty-year sentence for attempted murder reduced to ten years after trial court failed to consider mitigating factors and remand time.
Criminal law – Attempted murder – Sentencing discretion – Guilty plea and extra-judicial confessions as mitigating factors – Consideration of time spent on remand – Appellate interference where trial court overlooks material mitigation.
23 October 2023
Failure to comply with committal and evidential formalities rendered key exhibits inadmissible, leading to quashing of conviction.
Criminal procedure – committal proceedings – requirement to list and read over witness statements/documents (s246 CPA) – failure to comply bars tendering at trial; Evidence Act s34B(2) – statements by absent witnesses must be read over and signed by maker and recorder; cautioned statements – compliance with s50(1)(a) time limits for interview and necessity for explanation/extension of time; inadmissible exhibits may be expunged and may warrant acquittal if they are essential to conviction.
23 October 2023
Failure to swear witnesses at the CMA vitiated the proceedings, requiring rehearing before another arbitrator.
* Labour law – CMA proceedings – duty to administer oath/affirmation – Oaths and Statutory Declarations Act (Cap 34) and GN. No. 67/2007 (rule 25(1) and rule 19(2)(a)). * Evidence – unsworn witness testimony – unsworn evidence amounts to no evidence and vitiates proceedings. * Procedural irregularity – failure to comply with mandatory procedure – nullification of award and remittal for rehearing. * Precedent – Tanzania Distillers decision distinguished; post‑Distillers authorities discount unsworn evidence.
19 October 2023
Visual ID, defective identification parade and unlawfully recorded cautioned statement rendered the murder convictions unsafe.
* Criminal procedure — Visual identification — Witnesses under stress at night; requirement for watertight identification (Waziri guidelines) — failure to show light intensity, early naming and consistency renders identification unsafe. * Identification parade — of little value where witnesses know suspects and no prior descriptive record; noncompliance with Police General Orders invalidates parade evidence. * Cautioned statement — must be recorded within statutory time and with proper custody chronology; failure to call arresting officer and recording outside time renders statement inadmissible. * Retrial — not ordered where prosecution’s case is fragmented and a retrial would allow filling of evidential gaps rather than correcting mere procedural defects.
18 October 2023
September 2023
Conviction quashed because key documentary exhibits were improperly admitted and remaining evidence was only suspicion.
Criminal law — admissibility of documentary exhibits — must be cleared, admitted and read out in court; failure renders exhibits inadmissible; expunged exhibits may undermine conviction; proof beyond reasonable doubt required — mere suspicion insufficient.
27 September 2023
Omission by a successor judge to assign reasons is not fatal absent prejudice to a party.
Civil procedure — Succession of trial judge — Order XVIII r.10(1) CPC — Requirement to assign reasons when successor takes over — Rule engaged where evidence has been recorded and witness demeanour observed — Failure to assign reasons fatal only if it causes prejudice; affidavits/interlocutory applications distinguishable.
27 September 2023
The court held the dispute was commercial and beyond the trial court's pecuniary jurisdiction, nullifying and quashing the proceedings.
* Commercial law – definition of "commercial case" under section 2 of the Magistrates' Courts Act; liability arising from business activities. * Civil procedure – jurisdictional limits of Resident Magistrate/District Court in commercial cases (section 40(3)(b)). * Remedy – nullification of proceedings and quashing of judgments where court lacks jurisdiction; liberty to refile. * Costs – parties to bear own costs when Court raises issue suo motu.
26 September 2023
High Court erred by quashing entire divorce decree instead of limiting error to asset division; matter remitted for asset determination.
* Family law – Divorce – Division of matrimonial assets – Whether alleged matrimonial misconduct disentitles a spouse from sharing assets – Proof required for misconduct affecting entitlement. * Appellate procedure – Powers of first appellate court – Jurisdiction to rehear evidence and determine issues of fact and law on record. * Procedural remedy – When to quash entire judgment versus vacating a specific erroneous finding; appropriateness of remitting matters to trial court.
26 September 2023
Non‑compliance with committal requirements vitiated the trial; weak visual identification evidence led to quashing conviction and release.
Criminal procedure – committal proceedings – mandatory compliance with s.246(2) CPA (reading and explaining witness statements) and s.289(1) notice – non-compliance renders witnesses incompetent; Identification evidence – visual ID at night – Waziri Amani guidelines – contradictions, failure to name at earliest opportunity, and omission to call material witnesses undermine reliability; Remedy – nullification of committal and trial, quash conviction and set aside sentence; Retrial – remand inappropriate where prosecution case is not watertight and retrial would amount to persecution; Territorial jurisdiction irregularity curable under s.387 CPA.
22 September 2023
A notice of appeal can be struck out where the intending appellant fails to take essential procedural steps within prescribed time.
* Civil procedure — Appeal procedure — Rule 89(2) Court of Appeal Rules — striking out notice of appeal where essential steps not taken. * Civil procedure — Time limits — Rule 90(1)–(3) Court of Appeal Rules — requirement to apply for and serve requests for certified copies in time; inability to rely on proviso absent compliance. * Process — service and absence of reply affidavit — failure to contest factual averments on delay.
20 September 2023
Stay of execution application struck out for being time-barred and failing to file mandatory Rule 11 documents.
* Civil procedure – stay of execution – Court of Appeal Rules r.11(4) (timeliness) and r.11(7) (required documents) – failure to comply renders application incompetent; * Rule 4 – discretionary cure not applied where application is time-barred; * Labour enforcement – execution of compliance order; * Application struck out; no costs in labour matters.
20 September 2023
CMA lacked jurisdiction because public servants must exhaust internal/public service remedies under section 32A before litigating.
* Labour law — Jurisdiction of the Commission for Mediation and Arbitration — Public servants employed by public corporations — Section 32A Public Service Act — Requirement to exhaust internal/public service remedies before invoking labour law remedies.
20 September 2023
Unexplained delay in naming the suspect rendered the complainant’s testimony unreliable, warranting quashing of convictions.
Criminal law – rape and impregnating a schoolgirl; credibility of complainant – unexplained delay in naming suspect; admissibility and PF3 non‑compliance with s.240(3) CPA; absence of DNA evidence not determinative; appellate re‑evaluation of evidence under s.4(2) AJA; hearsay concerns and failure to consider defence.
18 September 2023
August 2023
Non-compliance with statutory committal requirements rendered trial evidence inadmissible; convictions quashed and matter remitted for fresh committal.
Criminal procedure – committal proceedings – requirement under section 246(2) CPA to read and explain information and substance of witnesses' evidence; admissibility of witnesses and exhibits at trial – need for reasonable notice under section 289(1) CPA when committal non-compliant; remedy – nullification of proceedings, quashing of convictions and remittal for fresh committal under section 4(2) AJA.
31 August 2023
31 August 2023
An unamended information naming absent co-accused rendered the trial a nullity; convictions quashed and retrial denied.
* Criminal procedure – defective information – naming absent co-accused – duty to amend under section 276(2) CPA – incurable defect vitiating trial. * Fair trial – accused must know the precise nature and particulars of the charge. * Power of court – section 4(2) AJA revisional powers – discretion to refuse retrial where further trial would be unjust. * Section 388 CPA not available to cure fundamental defects prejudicing the accused.
31 August 2023
A registered certificate of title is prima facie conclusive; unregistered interests require proof of prior possession or notice; damages set aside.
* Land law – Registered title – Certificate of title is prima facie/conclusive evidence of ownership; may be rebutted by proof of prior interest and possession or notice. * Land law – Unregistered interests – Section 33(1)(b) (Land Registration Act) preserves unregistered interests but requires proof. * Evidence – Parol evidence rule applies: oral evidence cannot vary or add to a written sale agreement pleaded as entire contract. * Remedies – General damages require factual assessment of causation and quantum; unsupported awards will be set aside.
30 August 2023
Inadequate summing up and defective admission of cautioned statements rendered murder convictions null and void; retrial declined.
Criminal procedure — summing up to lay assessors — adequacy and essential elements; assessors' opinions — compliance with s.298(1) CPA; repudiated cautioned statements — requirement for corroboration and proper admission; duty to give reasons when overruling objections; retrial — interest of justice.
30 August 2023
High Court wrongly decided appeal on merits after declaring it incompetent and denying parties their right to be heard.
Civil procedure – preliminary objection – competence of appeal – High Court sustaining preliminary objection then deciding merits – functus officio – revisional versus appellate jurisdiction – right to be heard – ex parte proceedings and setting aside.
29 August 2023
Conviction for impregnating a secondary school girl upheld; 30-year statutory maximum reduced to ten years as excessive.
* Education Act s.60A(3) – offence of impregnating a primary/secondary school girl – statutory maximum sentence versus mandatory penalty; sentencing discretion. * Evidence – sufficiency and corroboration: victim testimony corroborated by parent, teacher (attendance register), police and clinical officer. * Identity and age – discrepancies in PF3 do not necessarily vitiate proof where oral evidence is consistent. * Procedure – failure to cross-examine and to give a defence may be treated as acceptance of prosecution case.
29 August 2023
Appeal incompetent where notice and proceedings were directed to a deceased respondent; proceedings quashed as nullity.
Civil procedure – service of process – proceedings instituted against a deceased person are incompetent and a nullity; Court of Appeal may invoke revisional powers (s.4(2) AJA) to quash void proceedings. Rules implicated: Tanzania Court of Appeal Rules 2009, r.84(1) and r.90(3).
28 August 2023
CMA proceedings where an advocate gave unsworn evidence were a nullity and were remitted for rehearing before another Arbitrator.
* Labour law – termination/constructive resignation – CMA procedures – witness testimony must be under oath – advocate acting as witness – evidence irregularity vitiates proceedings – nullity and remittal to CMA for rehearing before a different Arbitrator.
28 August 2023
A timely alibi and material doubts in the prosecution case raised reasonable doubt, leading to quashing of the rape conviction.
Criminal law – rape – sufficiency and credibility of complainant’s evidence; defence of alibi – evidential burden shifts to prosecution once alibi is timely and particularised; appellate review of concurrent findings – interference justified where misdirection/non-direction and reasonable doubt apparent.
25 August 2023