High Court Corruption and Economic Crimes Division - 2018

66 judgments
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66 judgments
Citation
Judgment date
December 2018
The Division lacked jurisdiction to hear the applicants' EOCCA bail application under s.29(4)(d); application struck out.
EOCCA s.29(4)(d) – allocation of jurisdiction for bail applications involving property ≥ TZS 10,000,000 – jurisdiction lies with the High Court (general registry) not necessarily the Corruption and Economic Crimes Division; EOCCA s.36(1) – prescribes conditions and manner of granting bail and must be read with s.29; jurisdictional defects are substantive; bail application struck out as incompetent where matter remains at committal stage.
10 December 2018
November 2018
Accused in an economic offence granted bail; court imposed cash/property security, sureties, surrender of travel documents, and reporting conditions.
* Criminal procedure – Bail under EOCCA (sections 29(4)(d) and 36(1)) – High Court jurisdiction where value exceeds TShs.10,000,000/=. * Bail as a right – presumption of innocence – refusal only where ends of justice would be defeated. * Conditions for bail – cash or immovable property security, sureties executing bonds, surrender of travel documents, reporting and jurisdictional restrictions (section 36(5)).
27 November 2018
Court granted bail under EOCCA for alleged unlawful possession of government trophies, subject to cash, sureties and reporting conditions.
* Criminal procedure – Bail – Application under Sections 29(4)(d) and 36(1) EOCCA – Competency and jurisdiction of Corruption and Economic Crimes Division where alleged economic offence value exceeds Tshs.10,000,000. * Criminal law – Offence: unlawful possession of government trophies – bailability; exercise of judicial discretion where respondent unopposed. * Bail conditions – cash/immovable security, sureties’ bonds, travel restrictions, surrender of travel documents, reporting and verification of sureties.
22 November 2018
High Court granted bail in an economic crime case, finding competence and jurisdiction under EOCCA, subject to specified conditions.
* Criminal law – Economic offences – Bail application under EOCCA – Jurisdiction of High Court where value of charged property exceeds ten million shillings and trial not yet commenced. * Criminal procedure – Competency of bail application under ss.29(4)(d) and 36(1),(5) EOCCA. * Bail conditions – monetary deposit or immovable property, sureties and reporting requirements; verification by Resident Magistrate’s Court.
22 November 2018
High Court granted bail in economic offence matter, imposing deposit and surety, travel and reporting conditions.
Economic and Organized Crime Control Act – Bail pending trial – Jurisdiction where value of property charged exceeds TSh 10,000,000 – Committal proceedings pending – Conditions of bail: deposit amount, immovable property, sureties, travel restrictions, surrender of travel documents, reporting and verification.
21 November 2018
Money laundering is statutorily non‑bailable and charge‑sheet defects are premature to decide in this bail application.
* Criminal procedure – Bail – Money laundering – Statutory bar on grant of bail for money laundering under amended s.148(5) CPA; * Procedure – Pretrial/committal stage – Challenge to charge sheet premature under s.234 CPA; * EOCCA – Jurisdiction in bail applications confined to statutory bail considerations.
13 November 2018
High Court granted bail under EOCCA with cash deposit, sureties, travel restrictions and reporting conditions to secure attendance.
* Criminal procedure – Bail – Economic offences under EOCCA – Jurisdiction of High Court to grant bail for offences involving property value above Tshs.10,000,000. * Bail conditions – deposit and sureties – application of sharing principle and consideration of section 36(5) EOCCA. * Rights – presumption of innocence and accused’s right to bail where offences are bailable. * Procedural – respondent’s non-objection and verification of sureties by Resident Magistrate.
9 November 2018
October 2018
Applicant charged with unlawful possession of government trophies admitted to bail subject to half-value deposit and stringent conditions.
* Bail – EOCCA ss.29(4)(d), 36(1) and 36(5)(a) – jurisdiction to hear bail applications; bail as a right subject to lawful conditions where alleged government trophies value exceeds Tshs.10,000,000/-. * Requirement of cash deposit equal to half the alleged value or acceptable immovable property; remainder secured by bonds; sureties; surrender of travel documents; reporting obligations.
31 October 2018
Court granted bail under EOCCA subject to specified financial security, sureties, passport surrender and reporting conditions.
Bail — jurisdiction under EOCCA ss 29(4)(d) & 36(1) — offences bailable — bail is ordinarily a right — conditions: cash deposit or immovable property, two sureties with bonds, surrender of travel documents, monthly reporting, permission to leave jurisdiction.
31 October 2018
High Court granted bail under EOCCA, requiring half-value cash deposit for government trophy exceeding Tshs.10 million.
* Criminal procedure – Bail – High Court jurisdiction under EOCCA s29(4)(d) and s36(1) where subordinate court declines due to property value; application of s36(5)(a) requiring half-value cash deposit for property worth Tshs.10,000,000 or more. * Bail is a constitutional right; seriousness of alleged offence alone does not bar bail. * Bail conditions: cash deposit/immovable property security, sureties, travel restrictions, reporting and verification.
29 October 2018
Bail application struck out where the Drugs Act made the trafficking charge non-bailable and EOCCA alone could not properly move the court.
Bail – Drugs Control and Enforcement Act – statutory non-bailable offences determined by weight threshold – procedural primacy of Drugs Act over EOCCA – section 29(4) importing section 148 CPA – bail applications not for trying merits of charges.
26 October 2018
Court granted bail in an economic crime case, imposing cash deposit, sureties, travel surrender and reporting conditions.
* EOCCA – Bail – Jurisdiction to entertain bail applications where charged property exceeds TShs10,000,000 – Sections 29(4)(d) and 36(1). * Bail – Bailability of offences of unlawful possession of government trophy and leading organized crime. * Bail conditions – Application of section 36(5) EOCCA when imposing conditions (cash deposit, sureties, surrender of travel documents, reporting requirements). * Allegations of police mistreatment and ill-health – put to strict proof and not sufficient to deny bail absent persuasive evidence. * Respondent’s lack of objection – relevant to assessment of flight risk/attendance.
23 October 2018
Court granted bail to applicants charged with economic offences, finding High Court jurisdiction where value exceeds ten million shillings.
* Economic offences – jurisdiction for bail – Corruption & Economic Crimes Division where value involved exceeds ten million shillings; * Bail pending trial – presumption of innocence and bailability of charged offences; * Bail conditions – cash/immovable security, sureties, surrender of travel documents, reporting and verification per EOCCA provisions.
15 October 2018
A valid DPP certificate under EOCCA s36(2) bars bail; absence of a seal is not fatal and applicants remain remanded.
* EOCCA s36(2) – DPP certificate objecting to bail – validity test (DPP v Ally Nuru Dirie) – in writing; states likely prejudice to safety/interest of Republic; relates to pending criminal case. * Absence of DPP seal not fatal if signed. * DPP not required to give reasons in certificate; certificate challenge permissible only for bad faith or abuse of process. * Constitutional challenge to s36(2) inappropriate in bail application; prior decisions uphold constitutionality.
11 October 2018
The applicant was granted bail under EOCCA after the High Court found jurisdiction and imposed cash, sureties, travel and reporting conditions.
Criminal procedure – Bail under EOCCA – Jurisdiction where charged property exceeds TSh 10,000,000 and absence of committal proceedings or DPP certificate; bailability and appropriate bail conditions (cash/immovable security, sureties, travel restrictions, reporting, verification).
4 October 2018
High Court granted bail in an economic offence (value >TSh10M) with conditions under the EOCCA.
* Criminal procedure – Bail – Economic and Organized Crime Control Act (EOCCA) – jurisdiction of High Court where value of charged property exceeds TSh10,000,000; * Bail conditions – use of cash deposit or immovable property, requirement of reliable sureties and bonds, surrender of travel documents, reporting and residence restrictions; * Procedural competency – bail application under sections 29(4)(d) and 36(1), and conditions under sections 36(5) and 36(6) EOCCA.
2 October 2018
Bail granted for economic offence under EOCCA where charged property exceeds TShs.10,000,000, subject to specified financial and reporting conditions.
Economic offences — Bail under EOCCA (ss. 29(4)(d), 36(1), 36(5)–(6)) — Jurisdiction where charged property value exceeds TShs.10,000,000 — Grant of bail in absence of prosecution objection — Conditions: cash deposit/immovable property, sureties, surrender of travel documents, OC-CID reporting, verification by Resident Magistrate.
2 October 2018
September 2018
An accused under the EOCCA charged with unlawful dealing in trophies is entitled to bail pending trial subject to stringent conditions.
* EOCCA – Jurisdiction of High Court (Corruption and Economic Crimes Division) to entertain bail under ss.29(4)(d) and 36(1) where alleged property exceeds TSh 10,000,000. * Criminal procedure – Bail is a right based on presumption of innocence; bailable offences under EOCCA. * Bail conditions – cash deposit/immovable property security (half of alleged value), two sureties with bonds, surrender of travel documents, reporting and movement restrictions, verification by Resident Magistrate.
28 September 2018
Accused acquitted where repudiated cautions, lack of corroboration and variance in drug quantity/date undermined the prosecution.
Criminal law — Drug trafficking — Repudiated caution statements — voluntariness and statutory recording period — need for independent corroboration — adverse inference for failure to call key witness — material variance in charge particulars (quantity/date) fatal to prosecution.
11 September 2018
High Court grants bail under EOCCA with conditions including security, sureties, travel document surrender, and reporting.
* Criminal procedure – Bail under EOCCA – Jurisdiction of High Court’s Corruption and Economic Crimes Division to hear bail application where trial pending in Resident Magistrate’s Court – Conditions of bail: cash/immovable security, sureties with bonds and ID/residency requirements, surrender of travel documents, reporting and verification by Resident Magistrate.
7 September 2018
August 2018
High Court granted bail under EOCCA, imposing statutory s36(5) and s36(6) conditions for loss exceeding Tshs.10 million.
Jurisdiction under EOCCA s29(4)(d) – bail applications where alleged loss exceeds Tshs.10,000,000; Procedural regularity – defective counter-affidavit struck for undated jurat; Bail as a right – offences bailable; Mandatory bail conditions EOCCA s36(5) (half cash deposit where property value ≥ Tshs.10M, surrender passport, appearance, movement restriction); Additional conditions EOCCA s36(6) (reporting, locality restrictions, verification of sureties).
29 August 2018
Applicant charged with economic offences granted bail pending trial, subject to cash/immovable security, sureties, travel surrender, and reporting.
* Criminal procedure – Bail under EOCCA – jurisdiction of High Court to hear bail applications for economic offences – applicability of sections 29(4)(d) and 36(1) of EOCCA. * Bail conditions – security amount or immovable property equivalent, reliable sureties with bond amounts, residency/identification requirements, surrender of passport, reporting to Regional Crimes Officer, verification by Resident Magistrate. * Procedural – absence of DPP objection considered in exercise of judicial discretion to grant bail.
21 August 2018
High Court granted conditional bail under EOCCA where alleged property value exceeded Tshs.10 million, applying statutory and discretionary factors.
Corruption/Economic Crimes – Bail under EOCCA – High Court jurisdiction where alleged property value exceeds Tshs.10 million; factors for bail: seriousness, stage of investigation, risk of absconding or evidence tampering; conditional admission to bail (deposit, sureties, travel restrictions, reporting).
14 August 2018
July 2018
Court grants bail in an EOCCA economic-offence matter, finding jurisdiction and imposing substantial cash/ surety conditions.
* Criminal procedure – Bail under EOCCA – Jurisdiction of High Court (Corruption and Economic Crimes Division) to grant bail where alleged economic loss exceeds statutory threshold; * Bailability – Offence of occasioning loss to a specified authority under paragraph 10(1) First Schedule and sections 57(1) and 60 of EOCCA is bailable; * Bail conditions – cash deposit/immovable property, reliable sureties (one government employee), surrender of travel documents, reporting and verification of sureties.
30 July 2018
Applicants charged under EOCCA granted bail with substantial deposits, sureties, travel-document surrender and reporting conditions.
* Criminal procedure – Bail – Application under EOCCA (sections 29(4)(d) and 36(1)) – Jurisdiction where value exceeds TShs 10,000,000. * Bail as a right – conditions for grant – security, sureties, surrender of travel documents, reporting obligations. * Economic offences – ensuring attendance where alleged large pecuniary loss exists.
30 July 2018
Applicant charged with forest offences granted bail; High Court imposed monetary, surety, attendance and jurisdictional conditions.
* Economic and Organized Crime Control Act – Sections 29(4)(d), 36(1), (5) and (6) – High Court jurisdiction to grant bail where Resident Magistrate lacks jurisdiction due to property value. * Bail – presumption of innocence – entitlement to bail for bailable offences. * Bail conditions – monetary deposit or immovable property as security; sureties; travel restriction; attendance requirement. * Forest Act offences – allegations of unlawful transport of government forest produce (mangrove wood and charcoal).
25 July 2018
Applicants charged with trafficking large quantities of drugs are not entitled to bail; quantities cannot be divided among co-accused.
Criminal law – narcotics – bail excluded where trafficking involves statutory threshold quantities; ‘sharing’ of seized quantity among jointly charged accused not permitted; non-retroactivity of subsequent lowering of statutory thresholds; proper enabling provisions for bail in drug cases (s.29(3) and s.148 CPA).
6 July 2018
Failure to endorse chamber summons under Advocates Act s44(2) is not fatal; omission is curable and objection dismissed.
Advocates Act s44(2) — endorsement requirement — applicability to documents prepared by unqualified person for gain (s43) — Interpretation of Laws Act s53(2) and s2(2) — meaning of "shall" — procedural irregularity curable — preliminary objection on point of law (Mukisa Biscuit principle).
4 July 2018
Applicants charged with economic offences granted bail subject to deposit, sureties, travel-document surrender and reporting conditions.
* Criminal procedure – Bail – Applicants charged with economic offence (causing pecuniary loss) granted bail – Court to be guided by section 36(5) EOCCA and presumption of innocence. * Consolidation – Miscellaneous economic causes consolidated where applications arise from same pending Economic Crime Case. * Bail conditions – Cash/immovable property deposit, two sureties (one government-employed), surrender of travel documents, reporting and verification by Resident Magistrate.
4 July 2018
Failure to cite both sections 29 and 36 of EOCCA renders the applicant’s bail application incompetent and is fatal.
* Criminal procedure – bail in economic crime cases – necessity to cite and apply together ss.29 and 36 EOCCA; non‑citation renders application incompetent. * Advocates Act s.44(2) – endorsement/signature requirement – non‑mandatory in all circumstances; defect may be curable where substantial justice not impeded. * Court Rules (Rule 6) – titling irregularity – curable procedural defect.
4 July 2018
Failure by the applicants to endorse the "drawn and filed" area is a curable procedural defect; objection dismissed.
Advocates Act s44(2) — endorsement of "drawn and filed" entries; read with s43; Interpretation of Laws Act s53(2) — "shall" not always imperative; curable procedural defects; preliminary objection dismissed.
4 July 2018
Failure to cite EOCCA s36(1) alongside s29(4)(d) renders a bail application incompetent and it was struck out.
Criminal procedure – Bail in economic crime cases – EOCCA ss.29(4)(d) and 36(1) must be read and applied together; non-citation of s.36(1) renders the application incompetent; Advocates Act s.44(2) endorsement requirement may be directory/curable where omission does not impede substantial justice.
4 July 2018
June 2018
An applicant's incorrect citation of the originating case number in bail papers is a minor curable defect; application competent.
• Criminal procedure – Bail under EOCCA s.29(4)(d) – requirement to show pending subordinate court case; • Pleadings – incorrect citation of originating case number – whether substantive or curable defect; • Evidence – annexed charge sheet and document titles may cure mis‑citation; • Procedure – striking out vs expunging paragraphs; court may proceed where no prejudice shown.
25 June 2018
The applicants' right to bail was upheld; bail granted with strict financial, surety and reporting conditions under s.36 of the Act.
Bail – Economic and Organized Crime Control Act – jurisdiction to hear bail applications – offences bailable – presumption of innocence – statutory bail requirements (s.36(5),(6)) – security by cash or immovable property – sureties and reporting conditions.
22 June 2018
A valid DPP certificate under EOCCA s.36(2) bars bail until withdrawn; court found certificate met validity tests.
Criminal procedure – EOCCA s.36(2) certificate by DPP – validity test: in writing; asserts likely prejudice to Republic’s safety/interests; relates to pending criminal case; no bad faith or abuse of process – effect: valid certificate bars bail until withdrawn.
22 June 2018
A valid notice of appeal by the DPP institutes an appeal and justified staying pending bail proceedings.
* Appellate jurisdiction – s.6(2) Appellate Jurisdiction Act – DPP’s right to appeal against High Court orders * Procedure – Rule 68(1) Court of Appeal Rules 2009 – notice of appeal institutes appeal * Stay of proceedings – effect of notice of appeal and whether interlocutory rulings are appealable * Bail – competency of DPP certificate objecting to bail and consequences of appeal
19 June 2018
Applicant charged with trafficking a large quantity of heroin denied bail because the offence is statutorily non-bailable.
* Criminal procedure – Bail – Application under S.29(4)(d) and S.36(1) EOCCA – Jurisdiction of High Court. * Drugs law – Drugs Control and Enforcement Act s.29(1) – Statutory prohibition of bail where trafficking involves heroin/manufactured drugs of 200 grams or more. * Bail law – Effect of charge particulars and statutory thresholds; no requirement that charges be proved at bail stage for prohibition to apply.
4 June 2018
Screening, documented chain-of-custody and lab confirmation proved trafficking; the accused convicted and sentenced to life imprisonment.
* Criminal law – Drug trafficking – Elements of trafficking and mens rea – Possession and concealment as evidence of knowledge and intent. * Evidence – Chain of custody – seizure, handing-over certificates, lab submission and signed seals – admissibility and reliability of exhibits. * Procedure – Lawful arrest and search at airport; language barrier does not vitiate lawful procedure when the accused was present and participated. * Forensic evidence – Preliminary reagent testing and confirmatory gas chromatography establishing identity and weight of narcotic.
4 June 2018
May 2018
DPP's written certificate must identify the specific pending criminal case; otherwise it is invalid and bail hearing proceeds.
Bail — DPP's certificate under s.36(2) EOCCA — validity tests: (1) in writing; (2) states safety/interests of Republic likely prejudiced; (3) must relate to a pending criminal trial or appeal; (4) vitiated if DPP acted in bad faith or abused court process — pari materia with s.148(4) CPA not automatically applicable; no affidavit required for certification.
21 May 2018
High Court granted bail in narcotics possession matter, finding jurisdiction and imposing strict surety and travel conditions.
* Bail – High Court jurisdiction to entertain bail where quantity of narcotics exceeds District Court jurisdiction; * Bail in narcotics possession – conditions to ensure attendance and public interest; * Application under Economic and Organized Crime Control Act and Drug Control and Enforcement Act; * Unopposed bail application where prosecution did not file a counter-affidavit.
18 May 2018
A valid DPP certificate denying bail (including during committal) precludes the High Court from determining the bail application.
* Criminal procedure – Bail – DPP certificate under section 36 EOCCA – validity requirements and effect on bail applications; interpretation of "pending trial" to include pre-trial/committal proceedings – formality of official crested paper not fatal to certificate's validity.
18 May 2018
High Court properly entertained bail under the Economic and Organized Crime Control Act and granted bail subject to specified conditions.
* Criminal procedure – Bail – High Court jurisdiction under the Economic and Organized Crime Control Act to entertain bail applications for offences in Resident Magistrate’s Court. * Bail conditions – monetary bond, local sureties, attendance obligation, restriction on movement, and approval of sureties by Resident Magistrate. * Offences – unlawful possession of government trophies and firearms.
18 May 2018
A valid DPP certificate (even with a minor typographical error) precludes grant of bail pending trial.
Bail — DPP certificate — validity requirements (written, prejudice to state interests, relates to case pending trial/appeal) — minor typographical errors curable — "pending trial" includes committal/pre-trial stages — valid DPP certificate precludes bail.
18 May 2018
Application to vary bail struck out for being improperly grounded and supported by a defective affidavit.
Bail — Variation of bail conditions — Procedural prerequisites — Properly moved application — Economic and Organized Crime Control Act ss.36,37; Criminal Procedure Act ss.148(3),150 — Defective affidavit and verification clause — Application struck out.
16 May 2018
Applicant charged with narcotics trafficking granted bail after expungement of improper affidavit paragraph and subject to conditions.
* Criminal procedure – Bail application – Illicit trafficking in narcotic drugs – Offence bailable; prosecution’s non-objection – Court grants bail with conditions. * Civil procedure – Affidavit practice – Affidavit must not contain legal argument or provisions of law; offending paragraph expunged but affidavit remains valid. * Bail conditions – Monetary bond; two sureties (one resident within jurisdiction); approval of sureties by magistrate/deputy registrar; obligation to attend trial.
15 May 2018
The Corruption and Economic Crimes Division has jurisdiction to hear bail applications under EOCCA ss.29(4)(d) and 36(1).
Constitutional/Statutory interpretation; EOCCA s.29(4)(d) and s.36(1); Corruption and Economic Crimes Division jurisdiction; purposive interpretation to avoid absurdity; preliminary objection on jurisdiction.
8 May 2018
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