High Court Corruption and Economic Crimes Division - 2021

26 judgments
  • Filters
  • Judges
  • Alphabet
Sort by:
26 judgments
Citation
Judgment date
December 2021
Court admitted first page of seizure certificate but expunged unsigned second page for lack of required signatures.
* Evidence — Seizure certificate — Admissibility — Wrong citation of statute not fatal unless prejudice shown; goes to weight. * Procedure — Emergency search (s.42 CPA) vs ordinary search (s.38 CPA) — mis-citation curable where procedure followed conforms to law. * Evidence — Chain of custody — identification by author and unique features can suffice at admissibility stage; gaps may be filled later. * Police procedure — PGO 226 — seizure report must list items and be signed by officer, occupier and witnesses; unsigned continuation may be expunged.
17 December 2021
Court overruled objections and admitted the 3rd accused’s cautioned statement as voluntary and admissible.
Evidence — cautioned statement — voluntariness; Criminal Procedure Act s.50(1)(a) and s.50(2) — delay and exceptions; admissibility — formal defects (wrong verification citation, omission of subsection, s.57/s.58 citation) — curable if no prejudice; proof of detention — role of detention register and witness credibility; trial‑within‑trial procedure under Evidence Act s.27(2).
14 December 2021
Accused acquitted because valuation, search and seizure, and chain of custody were defective.
* Criminal law – unlawful possession and dealing in government trophies – burden to prove particulars including equivalence and valuation of tusks. * Evidence – valuation evidence and exchange rate must be substantiated. * Search and seizure – correct statutory basis (section 38 vs 42 CPA), authenticity of certificate of seizure and contradictions undermine admissibility. * Chain of custody – broken where search/seizure procedures are defective. * Confession – extra-judicial statement must contain admissions of essential ingredients to be admissible.
1 December 2021
November 2021
Retendering a formerly identified but rejected document is permitted; functus officio, issue estoppel, and disposal order objections overruled.
Criminal procedure – admissibility of exhibits – trial‑within‑trial – identification v. tendering as exhibit – functus officio – issue estoppel – section 353(3) CPA and Exhibit Management Guideline – chain of custody – administrative release by court registry.
22 November 2021
Whether a copied prosecutorial letter is admissible and whether a police witness can tender it without dispatch proof.
* Evidence — Documentary evidence — Authentication by unique features and chain of custody — Identification of witness’s name and force number as unique features. * Evidence — Competence of witness to tender exhibits — Oral possession and recognition may suffice absent disproof. * Evidence — Chain of custody — Paper trail not mandatory where limited handling and credible oral account exist. * Evidence — Use of document contents during admission — Content may be referred to for testing competence though full reading awaits admission.
15 November 2021
Wrong citation on a seizure form does not invalidate it unless the accused shows actual prejudice.
* Evidence — Search and seizure — Admissibility of statutory seizure certificate — Effect of wrong citation of enabling provision — overriding objective and prejudice test. * Statutory interpretation — Meaning of Swahili phrase "iliyorekebishwa" — construed as "as amended." * Criminal procedure — Difference between defects in motion documents and evidentiary documents — chain of custody and prevention of fabrication.
9 November 2021
Second appeal dismissed: new factual grounds cannot be raised and appellant failed to prove ownership.
* Civil appeals – second appeal – new factual grounds not raised in lower courts – inadmissible on appeal. * Evidence – documentary evidence – weight of sale agreement versus pension payment documents. * Burden of proof – party alleging ownership must prove it. * Appellate review – no interference absent extraordinary circumstances.
4 November 2021
October 2021
29 October 2021
27 October 2021
Whether a cautioned statement recorded after delay was admissible given investigative travel and allegations of torture.
Criminal procedure — Admissibility of cautioned/confession statement — s.50(1)(a), s.50(2) exception for time spent on investigative activity and conveyance — s.51 inapplicable where no prior interview began; voluntariness and torture allegations — trial-within-trial on admissibility.
20 October 2021
September 2021
Extension of time denied where applicant failed to account for delay and alleged illegality was not established.
Land appeal — extension of time to appeal; requirements under Lyamuya (account for delay, absence of inordinate delay, diligence, or sufficient reasons such as established illegality); overriding objective principle — cannot cure mandatory procedural defects affecting tribunal composition and right to be heard.
30 September 2021
24 September 2021
Prosecution’s circumstantial and electronic evidence was unreliable; case dismissed and the accused acquitted.
Criminal law – Organized crime and theft charges arising from a train accident; circumstantial evidence must be watertight; chain of custody and proper seizure of exhibits essential; cyber‑forensic evidence must be authenticated (hash values, reliable timestamps); cautioned statements and altered documents may be unreliable without proper explanation; expert evidence (mechanical/engineering) necessary to resolve technical causation issues.
21 September 2021
Counts under section 4(3)(i)(i) must expressly plead acts were made for the purpose of advancing or supporting terrorism; defective counts must be amended.
* Criminal procedure – preliminary objections – sufficiency and form of charge sheet in terrorism cases; requirement to plead purpose under s.4(3)(i)(i) of the Prevention of Terrorism Act, 2002. * Criminal law – conspiracy vs substantive offences – duplicity/multiplicity and double jeopardy. * Statutory construction – 'terrorist intention' and limits of judicial intervention versus parliamentary record (Hansard).
6 September 2021
The Corruption and Economic Crimes Division has jurisdiction to try terrorism offences after purposive reading of amendments classifying them as economic offences.
* Jurisdiction – Corruption and Economic Crimes Division – whether it may try offences under the Prevention of Terrorism Act after Act No. 3 of 2016 amended Cap 200 (paragraph 24). * Statutory interpretation – purposive construction and doctrine against absurdity where two statutes appear to confer jurisdiction. * Exclusivity – absence of express exclusivity means concurrent jurisdiction may exist; unamended provisions do not necessarily oust Division's jurisdiction.
1 September 2021
August 2021
Applicant’s satisfactory explanation for non‑appearance justified setting aside dismissal and restoring the appeal with no costs.
Civil Procedure — setting aside dismissal for want of prosecution — Order XXXIX r.19 CPC; sufficiency of reasons for non‑appearance; conduct before dismissal; registry communication failures; interest of justice; no prejudice to respondent.
31 August 2021
Unproven illness and unexplained 46-day delay precluded extension of time to appeal; application dismissed with costs.
Extension of time – sufficient cause – need to account for every day of delay; medical evidence – adequacy of medical letter, need for corroborating documents; pleadings and evidence – submissions not substitute for affidavit; old age not per se sufficient ground for extension.
16 August 2021
July 2021
Appellant failed to prove prior mortgage or title; mortgagee lawfully auctioned the encumbered property; appeal dismissed.
Land law – mortgage – validity of mortgage and priority; capacity to pass title while property encumbered; auction by mortgagee under section 126(d) Land Act; burden of proof – section 110 Evidence Act; appellate interference with tribunal findings; evidential weight – Hemedi Said v Mohamedi Mbilu.
30 July 2021
Prosecution failed to prove drug charges due to broken chain of custody and a defective cautioned statement.
* Criminal law – Drugs – Trafficking and possession – requirement to prove chain of custody from seizure to laboratory analysis – unexplained delay and missing handing-over documentation undermining admissibility and reliability of exhibits. * Criminal procedure – Cautioned statement – statutory requirements for reading, certification and timing – non-compliance renders statement unreliable.
27 July 2021
An application to restore a dismissed suit filed after the court-ordered deadline without leave was time-barred and dismissed with costs.
* Civil procedure – Restoration of dismissed suit – Compliance with court-ordered deadline – Filing after court-imposed date without leave is incompetent and time-barred. * Court orders – Time limits fixed by court – Parties must obey orders to ensure efficient administration of justice. * Preliminary objection – Time bar – Dismissal with costs where application filed out of time and without leave.
13 July 2021
Land claim dismissed as time‑barred: cause of action accrued in 2003; 12‑year limitation expired before suit.
* Limitation of actions – Land – Item 22 Part I Schedule to the Law of Limitation Act – 12‑year period for recovery of land – accrual of cause of action determined by pleadings and annexures. * Pleadings – plaint read with annexures to ascertain when plaintiff became aware of dispute. * Revocation of right of occupancy – effect on third parties and need to prove title against grantee before pursuit of claim against State.
6 July 2021
June 2021
First accused convicted for unlawful possession of elephant tusks; second acquitted; tusks forfeited; 20-year sentence.
* Wildlife offences – unlawful possession of government trophy – identification and valuation of elephant tusks – evidential value of expert identification and valuation certificate. * Possession – actual versus constructive possession – signing of certificate of seizure as acknowledgement of possession. * Chain of custody – exhibits not easily tampered with (elephant tusks) – oral testimony sufficient to establish continuity. * Procedural defence requirements – alibi particulars under section 42 EOCCA; shifted burden to prove lawful possession under section 100(3)(a) of the Wildlife Conservation Act. * Acquittal where no evidence links accused to alleged exhibit transfer or control.
17 June 2021
April 2021
Accused acquitted where prosecution failed to prove possession and maintain an unbroken chain of custody for narcotics.
Criminal law – Drug offences – Trafficking – Possession; Evidence – Burden of proof in criminal cases; Chain of custody – documentation and handling of narcotic exhibits; Failure to call material independent witness – adverse inference; Improper/disputed disposal and delay before laboratory analysis.
30 April 2021
Accused convicted of trafficking 327.56 kg cannabis; forensic proof and chain of custody upheld, each sentenced to 30 years.
* Criminal law – Narcotic drugs – Trafficking in cannabis sativa (327.56 kg) – Proof beyond reasonable doubt; forensic analysis confirming nature of substance. * Evidence – Chain of custody – exhibit register and submission forms established continuity of custody. * Procedure – Arrest and seizure – lawful though formal seizure recorded at police station due to unsafe scene. * Defence credibility – alibi of looking for plots and allegations of coercion unsubstantiated and rejected. * Sentence – 30 years imprisonment each; exhibits destroyed; vehicle dealt with under relevant rules.
16 April 2021
March 2021
Court convicted the accused of heroin trafficking, upheld searches and chain of custody, imposed life sentences, destroyed drugs and confiscated the vehicle.
* Criminal law – Narcotic drugs – Trafficking in heroin hydrochloride – Proof of recovery and identification of exhibits – admissibility and sufficiency of chemist's analysis. * Evidence – Search and seizure – credibility of police and independent witness testimony; allegations of planting require particularisation. * Evidence – Chain of custody – absence of paper trail does not necessarily break chain where oral custody evidence is credible. * Confiscation and disposal – Court power to order destruction of narcotics and confiscate instrumentality of offence despite an intended appeal. * Sentencing – Statutory life sentence for trafficking offences; limited or no discretion for leniency in such offences.
31 March 2021
February 2021
An extension application was dismissed as res judicata because a competent High Court registry had already decided the same matter.
* Civil procedure – res judicata – application for extension of time – identical application previously heard and decided by same court registry precludes relitigation.* Procedural remedy – certificate of delay; registrar assistance and referral to legal aid.
19 February 2021