High Court Corruption and Economic Crimes Division - 2018 April

8 judgments
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8 judgments
Citation
Judgment date
April 2018
A valid DPP certificate previously upheld bars the Court from granting bail; fresh bail application struck out.
* Criminal procedure — Bail — Effect of a DPP certificate under EOCCA s36(1)-(3) — Valid certificate bars grant of bail while in force. * Doctrine of functus officio — Finality of decisions; interlocutory rulings do not necessarily render court functus officio. * Subsequent bail applications — Improper if prior grounds are static and unchanged; change of circumstances or lifting of certificate may justify rehearing. * Practice — Proper practice is to bring subsequent bail applications before the same judge where practicable.
18 April 2018
A DPP's bail-objection certificate is invalid if it fails to correctly identify the pending criminal case.
EOCCA s36(2) — DPP’s certificate objecting to bail — validity tests (Dirie/Li Ling Ling/Massawe) — requirement to relate to a specific pending case — incorrect case citation renders certificate invalid — bail application to be heard on merits.
17 April 2018
Applicants charged with economic and explosives offences granted bail subject to substantial cash/title security, sureties, reporting and travel restrictions.
* Criminal procedure – Bail pending trial under the Economic and Organized Crime Control Act – whether offences are bailable and appropriate bail conditions. * Bail security – cash deposit equal to half the value of property involved where value exceeds Tshs.10 million; alternative immovable property security with title, valuation and Registrar approval. * Sureties and conditions – requirement of two reliable sureties (each bond Tshs.5,000,000), travel restriction, monthly reporting and court attendance.
17 April 2018
Applicants charged with unlawful possession of government trophies admitted to bail subject to deposit, sureties and travel restrictions.
* Criminal procedure – Bail – Admission to bail for economic offences involving government trophies – Jurisdiction under EOCCA where property value exceeds TShs.10,000,000 – Conditions including cash/immovable deposit, sureties and travel restrictions.
12 April 2018
DPP's certificate objecting to bail upheld despite titling errors; bail refused under section 36(2)–(3) EOCCA.
* Criminal procedure – DPP certificate under section 36(2) EOCCA – competency and validity tests; effect of procedural/formal defects in titling; timing of filing and prejudice; evidential requirement for allegations of bad intent.
12 April 2018
Bail application struck out after court found DPP's s.36(2) certificate valid and operative.
* Criminal procedure – bail – DPP's s.36(2) EOCCA certificate – validity test (written; states safety/interest likely prejudiced; relates to criminal proceedings) – effect under s.36(3) – court cannot grant bail once valid certificate filed unless withdrawn or proceedings conclude. * Challenges of bad faith, delay, or requirement for detailed reasons require evidence; constitutional/parimateria challenges belong in appropriate forum.
11 April 2018
A valid DPP certificate under s.36(2) EOCCA bars bail and the court must strike out the bail application until proceedings conclude.
* Criminal procedure – DPP certificate under s.36(2) EOCCA – validity requisites (in writing; certifies prejudice to safety/interests; relates to pending proceedings) – bad faith/abuse as exception. * Statutory interpretation – in pari materia principle not applied where Court of Appeal recently declined to do so in criminal context. * Bail – effect of valid DPP certificate: court precluded from admitting accused to bail until withdrawal or conclusion of proceedings.
10 April 2018
Court granted bail to two applicants with conditions and required the foreign applicant to prove a fixed abode before bail.
* Criminal procedure – Bail – right to bail where offences are bailable – primary consideration is availability and adequate security. * Jurisdiction – High Court jurisdiction under EOCCA for committal/bail applications in economic offences. * Foreign nationals – nationality alone not determinative; absence of fixed abode relevant to risk of non‑attendance. * Evidence – affidavit evidence required; oral submissions cannot substitute replies to counter‑affidavits. * Conditions – cash/immovable security, reliable sureties, surrender of travel documents, reporting and verification obligations.
5 April 2018