High Court Corruption and Economic Crimes Division - 2018

66 judgments
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66 judgments
Citation
Judgment date
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relates to criminal proceedings) – effect under s.36(3) – court cannot grant bail once valid certificate filed unless withdrawn or proceedings conclude.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
March 2018
A valid DPP certificate under s.36(2) EOCCA bars bail unless withdrawn or special circumstances justify override.
* Criminal procedure – Bail – Effect of Director of Public Prosecutions’ certificate under s.36(2) EOCCA – Validity tests (in writing; safety/interests of Republic; relates to pending/awaiting trial) and timing of filing. * Filing formalities – No prescribed format for DPP certificate; court stamp and official crest sufficient to show presentation. * Challenge to DPP certificate – Burden to prove bad faith, abuse of process or special circumstances to override certificate.
15 March 2018
Subsequent bail application struck out because a valid DPP certificate remained operative, so reasons for prior refusal persisted.
* Criminal procedure – Bail – Subsequent bail application – Competence of same court where earlier bail refused due to DPP certificate; * Doctrine of functus officio – applicability where matter finally determined; * Preliminary objection – point of law under Mukisa principle; * Requirement of change of circumstances or withdrawal of DPP certificate before rehearing.
14 March 2018
Verification clause naming 'applicant' instead of 'deponent' rendered affidavit incurably defective; bail application struck out.
* Civil procedure – Affidavit requirements – verification clause must be signed by the deponent and authenticate source of facts; omission of 'deponent' may render affidavit defective and incurable. * Evidence – Jurat and verification – jurat and verification are distinct ingredients; both must properly identify the deponent. * Civil procedure – Preliminary objection – procedural non‑compliance as a point of law to be determined before merits. * Amendment – Verification clause defects generally not amendable where they affect authentication of facts.
14 March 2018
High Court granted bail in an economic offence matter, imposing EOCCA-prescribed financial and reporting conditions.
Economic offences — Bail — Jurisdiction under EOCCA ss.29(4)(d) & 36(1); Competency of bail application; Conditions under EOCCA ss.36(5) & (6) — deposit of half property value; sureties and bonds; surrender of travel documents; reporting obligations.
13 March 2018
Bail refused because alleged heroin amount (375.20g) exceeds statutory 20g threshold rendering the offence non-bailable.
* Criminal procedure – Bail – Drug trafficking – Section 29(1)(a) Drug Control and Enforcement Act: trafficking listed narcotics of 20 grams or more is non-bailable; evidential questions of type and weight are for trial, not bail stage. * Evidence – Role of Government Analyst – Court will not call or require substantive proof of drug type/weight at bail as it would amount to premature trial. * Civil procedure – Counter-affidavits – Failure to file counter-affidavit does not preclude legal opposition at hearing where matters are legal rather than factual.
9 March 2018
February 2018
Statutory 30‑litre precursor‑chemical threshold bars bail; High Court must dismiss the bail application.
* Criminal procedure – Bail – Drug Control and Enforcement Act, s.29(1)(c) – statutory prohibition of bail where accused charged with precursor chemicals of 30 litres+ (liquid) or 30 kg+ (solid). * Statutory interpretation – "precursor chemical" defined as chemical used in manufacturing narcotic drugs or psychotropic substances; no ambiguity warranting favourable construction at bail stage. * Jurisdiction – Corruption and Economic Crimes Division is the court referenced by s.29(1) and therefore bound by its bail prohibition. * Evidentiary issues (whether a substance is a precursor) are for trial, not bail proceedings.
28 February 2018
A DPP certificate under section 36(2) EOCCA cannot automatically bar judicial consideration of a bail application.
Criminal procedure — Bail — DPP certificate under s36(2) EOCCA — Parimateria with s148(4) CPA — Mtobesya’s ruling — Prosecutorial duties (s8 National Prosecution Services Act) — Timing and reasons for certificate — Judicial jurisdiction to hear bail applications.
26 February 2018
January 2018
A valid DPP certificate under EOCCA s36(2) justifies refusal of bail; the DPP need not state reasons.
Bail — DPP certificate under EOCCA s36(2): validity requirements (written/signed; states likely prejudice to Republic; relates to pending criminal case); DPP not required to give reasons; certificate sustains refusal of bail; effect extended under s36(3).
11 January 2018
A valid DPP certificate under EOCCA s36(2) bars bail; EOCCA s36(2) remains effective and the bail application was denied.
* Criminal procedure – Bail in economic offence cases; jurisdiction where property value is >= TZS 10,000,000; EOCCA s36(1)/(2)/(3). * DPP certificate – validity requirements: in writing, effect on safety/interests of the Republic, relates to pending proceedings (Ally Nuru Dirie; Li Ling Ling). * Filing formalities – court stamp and issuer signature sufficient; clerk's signature not essential. * Constitutional challenge – EOCCA s36(2) distinguishable from CPA s148(4) and not struck down by that decision.
11 January 2018
High Court granted bail in an economic crimes matter under EOCCA, imposing substantial security, sureties, reporting and travel restrictions.
Economic Crime – Bail – Jurisdiction of High Court under EOCCA sections 29(4)(d) and 36(1) – Bailability of offences – Judicial discretion in granting bail – Conditions: substantial cash/immovable security, government-employed surety, surrender of travel documents, reporting and verification.
11 January 2018
High Court granted bail in a high-value economic crimes case, imposing deposit, sureties, travel restrictions and reporting conditions.
* Economic and Organized Crime Control Act (EOCCA) – jurisdiction over bail applications where charged property value exceeds Tsh 10,000,000; * Bail – entitlement for bailable economic offences; * Bail conditions – deposit, sureties, surrender of travel documents, reporting and verification; * Presumption of innocence and ensuring accused’s attendance at trial.
9 January 2018
A valid DPP certificate under EOCCA bars grant of bail in economic crime cases pending trial.
* Economic crime — Bail — Jurisdiction under EOCCA s.29(4)(d) and s.36(1) where committal pending and amount exceeds TSh10,000,000; * Director of Public Prosecutions — Certificate under EOCCA s.36(2) — Validity test (written; states likely prejudice to safety/interests of the Republic; relates to pending criminal case) — Effect: bars grant of bail; * Requirement of reasons — DPP not obliged to provide detailed reasons in certificate; * Constitutional challenge — Proper forum required to impugn s.36(2) or DPP conduct.
8 January 2018