High Court Corruption and Economic Crimes Division - 2020

34 judgments
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34 judgments
Citation
Judgment date
December 2020
18 December 2020
15 December 2020
8 December 2020
Unreliable identification and lack of corroboration raised reasonable doubt, resulting in acquittal on wildlife poaching charges.
* Criminal law – Identification evidence – observations made at 100m amid shrubs and trees; contradictions in witness descriptions render identification unsafe and require caution. * Evidence – Corroboration – where identification is weak, corroborative evidence is necessary to sustain conviction. * Defence – Alibi – properly raised alibi, supported by witnesses and documents, can create reasonable doubt. * Wildlife law – Prosecution must prove unlawful hunting and dealing beyond reasonable doubt; seized exhibits may be confiscated under s.101 Wildlife Conservation Act.
3 December 2020
November 2020
20 November 2020
16 November 2020
16 November 2020
Possession of an elephant tusk was proved, chain of custody upheld, alibi rejected; convicted, sentenced to 20 years and tusk forfeited.
Wildlife offences – unlawful possession of government trophy (elephant tusk); evidentiary proof of possession; chain of custody requirements and admissibility; late alibi and statutory notice under economic offences statutes; sentencing and forfeiture under Wildlife Conservation Act and Economic and Organized Crime Control Act.
13 November 2020
10 November 2020
6 November 2020
September 2020
Accused convicted of unlawful possession of heroin hydrochloride; chain of custody upheld despite detention irregularities.
* Drug offences – identity of substance – heroin hydrochloride confirmed by Government Chemist as narcotic drug; section 15(2) covers substances with drug effects not expressly listed. * Search and seizure – seizure certificate and independent witness statement corroborate retrieval from accused. * Chain of custody – oral testimony and exhibit markings upheld continuity despite documentary gaps. * Procedural irregularity – detention beyond 48 hours noted but did not vitiate admissible evidence. * Conviction on alternative count of unlawful possession; sentence imposed.
18 September 2020
8 September 2020
8 September 2020
August 2020
Prosecution proved unlawful possession of an elephant tusk; chain of custody intact and accused convicted, fined or imprisoned.
Wildlife offences — unlawful possession of government trophy (elephant tusk); admissibility and weight of certificate of seizure; chain of custody and exhibit integrity; statutory notice/particulars for alibi; effect of failure to cross-examine and afterthought defences; forfeiture and sentencing under Wildlife Conservation Act and Economic and Organized Crime Control Act.
18 August 2020
Court convicted two accused for unlawful possession of three elephant tusks; chain of custody held unbroken.
* Wildlife offences – unlawful possession of government trophies (elephant tusks) * Possession – actual and constructive possession principles applied * Evidence – validity of on-scene seizure and signed seizure certificate * Chain of custody – documentary and oral proof sufficient despite minor inconsistency * Sentencing – heavy statutory penalties; forfeiture of exhibits under Wildlife Conservation Act
17 August 2020
6 August 2020
July 2020
Accused acquitted where identification and disposal of perishable exhibits were unreliable and alibi raised reasonable doubt.
Wildlife offences — proof beyond reasonable doubt — visual recognition evidence — caution in reliance on recognition at distance — retracted cautioned statement requires corroboration — disposal of perishable exhibits must involve accused and comply with procedure before evidential reliance.
24 July 2020
Accused convicted for unlawful possession and sale of a government trophy; chain of custody and statutory burden of proof considered.
* Wildlife Conservation Act – unlawful possession and dealing in government trophy; identification and valuation of elephant tusk. * Documentary and oral proof of chain of custody – seizure and handing‑over forms sufficient for items not easily tampered with. * Burden under s.100(3) shifts to accused to prove lawfulness on balance of probabilities. * Sentencing – statutory minimum under EOCCA s.60(2) applied.
23 July 2020
Acquittal due to broken chain of custody and disparity between charge particulars and prosecution evidence regarding possession of trophies.
* Wildlife offences – unlawful possession, dealing and transfer of government trophies; chain of custody; admissibility of seizure certificate under Wildlife Conservation Act; authorised officer requirement; effect of variance between charge particulars and evidence; failure to call material witness.
20 July 2020
10 July 2020
Acquittal where defective seizure procedures, missing exhibit labels and broken chain of custody raised reasonable doubt.
* Criminal law – narcotics – identification of substances – admissibility of Government Chemist evidence; * Evidence – chain of custody – requirement for exhibit labeling, packing materials and independent witness; * Procedure – certificate of seizure should be signed at scene in presence of independent witness; * Confession – oral confessions require cautioning and corroboration; * Burden – prosecution must prove guilt beyond reasonable doubt.
6 July 2020
May 2020
Perishable trophy disposed without proper procedure or accused present; prosecution failed to prove offences beyond reasonable doubt.
Wildlife law – unlawful hunting and possession of government trophy; perishable exhibits – disposal procedure under WCA s.101, EOCCA s.23 and PGO No.229 para.25; accused’s right to be present and heard before disposal; burden of proof in criminal trials; alibi notice requirements under EOCCA s.42.
11 May 2020
Prosecution failed to prove hunting or unlawful possession where disposal of perishable trophy breached required procedure and evidence was inadequate.
Wildlife Conservation Act – unlawful hunting and unlawful possession of government trophy; perishable exhibits – statutory and procedural safeguards for disposal; requirement that accused be present and heard before disposal order; evidential consequences of failure to seize remains; burden-shifting under WCA regarding licence/permit.
11 May 2020
8 May 2020
April 2020
29 April 2020
17 April 2020
Acquittal due to invalid seizure documentation and a broken chain of custody undermining prosecution's case.
* Criminal law – narcotic drugs – proof of possession and trafficking – requirement to prove possession beyond reasonable doubt; burden under s.28 DCEA shifts to accused to show lawful possession on balance of probabilities. * Evidence – certificates of seizure – must be completed and signed at the scene and, where required, witnessed independently to have evidential weight. * Evidence – extra‑judicial statement – a retracted statement is not a confession and requires corroboration. * Evidence – chain of custody – documentation or watertight oral testimony required to exclude tampering; contradictions and unexplained gaps break the chain.
8 April 2020
March 2020
27 March 2020
6 March 2020
6 March 2020
6 March 2020
6 March 2020
February 2020
28 February 2020
18 February 2020