High Court Corruption and Economic Crimes Division - 2017

18 judgments
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18 judgments
Citation
Judgment date
December 2017
A valid DPP Certificate under s.36(2) EOCCA bars bail; "pending trial" includes pre-trial stages, so bail application dismissed.
* Criminal procedure – Economic and Organized Crimes Act s.36(2) – DPP Certificate barring bail – validity and requirements. * Interpretation of "pending trial" – Li Ling Ling interpretation includes arrest and committal stages; Certificate can be lodged pre-trial. * Procedural form – s.36(3) prescribes duration but need not be cited as enabling provision. * Disclosure – DPP not required to specify nature of threatened prejudice to safety or public interest.
7 December 2017
November 2017
A valid DPP certificate under s36(2) bars courts from granting bail pending trial when conditions are met.
* Economic and Organized Crimes Control Act s36(2) – DPP certificate barring bail; Criminal Procedure Act s148(4). * Validity requirements for DPP certificate (written; safety/interests prejudice; relates to pending trial or appeal) – per Li Ling Ling and Dirie. * Prematurity challenge of certificate – certificate may be valid before plea if case is pending trial. * Bail – court bound not to grant bail where valid DPP certificate exists. * Constitutionality challenge – issue for constitutional forum; DPP not required to disclose nature of claimed interest.
20 November 2017
High Court grants bail for an economic offence subject to statutory financial and surety conditions despite minor citation errors.
Corruption & Economic Crimes Division — Bail for economic offences; value threshold (TShs.10,000,000+) — statutory special conditions (deposit half value or approved immovable property; two sureties; surrender travel documents) — substantial justice over technical citation errors — High Court jurisdiction to hear EOCCA bail applications.
16 November 2017
Applicants charged with trafficking 27.09 kg cannabis granted bail with stringent conditions; citation omission not fatal.
* Criminal procedure – Bail – Trafficking in narcotic drugs – Quantity-driven bailability under s.29(1) Drugs Control and Enforcement Act – Conditions for grant of bail (bonds, sureties, surrender of travel documents, territorial restriction, court attendance). * Jurisdictional citation – Failure to cite amending Act No.3/2016 improper but not fatal to application.
6 November 2017
October 2017
Applicant failed to show sufficient cause or act expeditiously; application for extension of time to appeal dismissed.
* Criminal procedure – extension of time to appeal – section 361(2) CPA – requirement of sufficient/good cause and expeditiousness. * Procedural compliance – notice of appeal – effect of notices filed within prescribed time. * Prison authorities’ assistance – absence of evidence that prison officers refused help not a ground for extension. * Alleged illegality – petition of appeal must disclose substantive illegality to justify extension of time.
18 October 2017
The Corruption and Economic Crimes Division has jurisdiction to hear s.29(4)(d) bail applications; speculative affidavit paragraphs expunged.
Corruption and Economic Crimes Division – Jurisdiction under s.29(4)(d) EOCCA post-2016 amendment; statutory and purposive interpretation to cure legislative anomaly; preliminary objections – point of law; affidavits – limits on advocates swearing evidence, expungement of speculative paragraphs.
11 October 2017
Applicants granted bail under EOCCA; court declined to consider merits and imposed stringent security and reporting conditions.
* Criminal procedure – Bail – EOCCA ss. 29(4)(d), 36(1) – entitlement to bail in economic crime matters; refusal to adjudicate merits at bail stage; imposition of substantial monetary security, sureties, passport surrender, reporting requirements and verification by lower court.
6 October 2017
Court varied bail by increasing deposit and adjusting surety requirements due to addition of accused and sharing principle.
* Criminal procedure – Bail – Variation of bail conditions where additional accused are joined – Application of the principle of sharing in fixing quantum of security. * Bail sureties – Requirement of two reliable sureties and bond amounts; one surety to be a public servant.
6 October 2017
September 2017
Court expunged defective affidavit paragraphs for extraneous matters and allowed the applicant’s application to proceed on merits.
* Procedure – Preliminary objection – when objection to competency of an affidavit raises a point of law and may be entertained. * Evidence/Affidavits – content limits: affidavits must state facts within deponent’s knowledge or information from specified sources; must not contain legal argument, conclusions or speculative opinion. * Affidavits – hearsay and anonymous sources; requirement to specify source when deposing on information. * Remedy – expunction of defective paragraphs where defects are inconsequential; defective verification may be academic after expunction.
26 September 2017
High Court granted bail in economic offences, imposing deposit, sureties, abode proof, travel surrender and reporting conditions.
Criminal procedure – Bail in economic offences – Jurisdiction of Corruption and Economic Crimes Division under EOCCA s.29(4)(d) and s.36(1); bail as a right for bailable offences; considerations where accused is a foreign national and lacks evidence of fixed abode; conditions for bail under EOCCA s.36(5)–(6) including monetary deposit, sureties, surrender of travel documents, and reporting requirements.
18 September 2017
August 2017
A valid DPP certificate under s36(2) EOCCA bars bail; bail court cannot probe charge particulars when not the trial forum.
DPP certificate (s36(2) EOCCA) — validity requirements (written; safety/interest prejudice; relates to pending criminal proceedings) — effect: bars grant of bail; High Court’s limited role in bail proceedings — cannot go into charge-sheet correctness where not trial court; allegations of abuse do not displace a valid certificate in bail application.
18 August 2017
High Court found itself functus officio and struck out fresh bail application where DPP's valid certificate previously barred bail.
Bail — DPP certificate under section 36(2) EOCCA — validity of certificate — effect of a valid DPP certificate barring bail — functus officio — finality of earlier High Court rulings — remedy by appeal to Court of Appeal.
17 August 2017
Wrong statutory citation and defective jurats rendered the bail application incompetent and it was struck out.
* Criminal procedure – bail application – wrong citation of enabling provision – incompetence of application. * Oaths and affidavits – jurat must state whether deponent personally known or introduced to Commissioner for Oaths – failure fatal. * Amendment after a substantive preliminary objection – not permitted to circumvent objection. * Affidavit formalities – date issue considered but not fatal where date appears.
10 August 2017
July 2017
Citing an irrelevant statute does not defeat a bail application if the proper EOCCA provision is cited; bail granted with conditions.
* Criminal procedure – Bail – Economic and Organized Crime Control Act (EOCCA) – section 29(4)(d) and section 36(5)(a) – lawful bail conditions including cash/property deposit and bond (Written Laws Misc. Amend. Act No.3 of 2016). * Procedural law – Effect of citing inapplicable statutes – superfluous citation harmless where proper enabling provision is cited and no prejudice shown. * Co-accused – sharing of financial burden for bail – application of principle of sharing.
5 July 2017
June 2017
A valid DPP certificate under s.36(2) ECOCCA prevents grant of bail until the DPP withdraws it.
* Criminal procedure – Bail – Effect of DPP certificate under s.36(2) ECOCCA – A valid certificate by the DPP precludes grant of bail until withdrawn. * Constitutional law – Article 107A does not empower court to ignore valid statutory DPP certificate. * Statutory interpretation – Similarity to s.148(4) CPA does not automatically render s.36(2) ECOCCA unconstitutional. * Validity test for DPP certificate – Written certification that safety/interests of the Republic likely to be prejudiced and relation to subordinate court proceedings (Ally Nur Dirie/Li Ling Ling authorities).
8 June 2017
May 2017
A valid DPP certificate under s.36(2) ECOCCA precludes the court from granting bail to the applicant.
* Criminal procedure – bail pending trial – DPP certificate under s.36(2) ECOCCA – effect of valid certificate prevents grant of bail. * Procedural requirements – DPP certificate is a standalone document; court stamp and original seal suffice. * Constitutional challenge – invalidity of similar provision in another statute (s.148(4) CPA) does not automatically negate s.36(2); Court of Appeal authority is binding.
17 May 2017
April 2017
Preliminary objection to the affidavit rejected, but a valid DPP certificate prevents granting bail while it stands.
* Criminal procedure – bail – DPP certificate under s.36(2) Economic and Organized Crimes Control Act – validity test (in writing; safety/interests likely prejudiced; relates to pending criminal case) – effect of certificate on court’s power to grant bail. * Affidavits – whether paragraphs constitute impermissible legal argument/conclusion or admissible factual statements and undertakings.
27 April 2017
March 2017
Applicant charged with unlawful possession of high‑value elephant tusks granted bail subject to financial and reporting conditions.
Bail — statutory right — jurisdiction under S.29(4)(d) EOCCA where subject matter exceeds TShs.10,000,000 — unlawful possession of government trophies (elephant tusks) — presumption of innocence — conditions for bail: financial security, reliable sureties (one public servant), surrender of travel documents, reporting and verification.
14 March 2017