High Court Corruption and Economic Crimes Division - 2021 December

3 judgments
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3 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