High Court Corruption and Economic Crimes Division - 2023

21 judgments
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21 judgments
Citation
Judgment date
December 2023
22 December 2023
22 December 2023
22 December 2023
22 December 2023
The applicant’s ignorance and counsel’s wrong advice do not constitute good cause to extend time to appeal.
* Appellate procedure – extension of time under s.11(1) AJA – discretion to grant extension – factors: length of delay, reasons, diligence, prejudice, and existence of a substantial/legal point (illegality). * Procedural law – ignorance of law/wrong advice by counsel does not constitute good cause for extension of time. * Criminal law – plea of guilty generally bars appeal against conviction; appeals allowable only for equivocal pleas or questions of illegality. * Evidence – grounds must be deposed in supporting affidavit; submissions from the bar are not evidence.
19 December 2023
19 December 2023
18 December 2023
14 December 2023
October 2023
Expert confirmed khat, but defective search and broken chain of custody led to acquittal.
* Criminal law – Drug trafficking – Identification of narcotics by Government Chemist – Analyst report prima facie conclusive; * Search and seizure – seizure certificate requirements and presence of (preferably independent) witness; * Evidence – chain of custody – continuity and integrity of exhibits from seizure to laboratory; * Prosecutorial duty – calling material witnesses and explaining custody/transportation of exhibits; * Failure to prove beyond reasonable doubt – acquittal and disposal/destruction of exhibits.
31 October 2023
August 2023
Conviction for trafficking upheld where search was lawful, chemist confirmed cannabis, and chain of custody remained intact.
Criminal law – Drugs – Trafficking – Lawful search by officer deputized as officer in charge without warrant – Admissibility and identification of seized drugs by government chemist – Chain of custody requirements – Proof beyond reasonable doubt.
21 August 2023
4 August 2023
July 2023
The respondents were acquitted due to broken chain of custody and insufficient proof of knowledge (mens rea).
* Criminal law – Drug trafficking – elements: possession, conveyance and requirement of proof beyond reasonable doubt. * Forensic proof – Government Chemist identification of cannabis sativa and weight confirmation. * Evidence – chain of custody critical; unexplained gaps may vitiate prosecution case. * Mens rea – knowledge or reason to believe may be necessary in particular circumstances despite possession. * Corroboration – uncorroborated implication by co-accused and similarity of names insufficient to convict.
24 July 2023
Conviction for khat trafficking: proper identification, lawful search, intact chain of custody, and conclusive lab report.
Criminal law - Trafficking in narcotic drugs (khat); identification at scene; search and seizure procedure under DCEA (s.48(2)(c)(vii)); certificate of seizure; chain of custody (handing-over certificates, PF16, lab submission); conclusive Government Chemist report (s.48A(2)); standard for reasonable doubt and assessment of defence evidence.
13 July 2023
Accused convicted for trafficking 529.05 kg khat; search, chain of custody and lab report upheld.
Drugs — Khat (Catha edulis) — search and seizure; certificate of seizure; chain of custody; Government Chemist report conclusive under s.48A(2) Cap 95; inventory and lawful destruction; alibi notice and failure to rebut laboratory evidence.
12 July 2023
Accused acquitted of drug trafficking due to broken chain of custody and material contradictions in seizure evidence.
Criminal law — Drug trafficking — Seizure and chain of custody — Labelling and exhibit register — Material contradictions undermining evidential chain; laboratory analysis insufficient where chain broken.
12 July 2023
June 2023
Court forfeited certain properties acquired within ten years post‑conviction; other assets discharged for insufficient proof.
* Proceeds of Crime – conviction‑based forfeiture – statutory presumption for properties acquired/developed within ten years under Drugs Control Act – burden to rebut by reasonable explanation. * Standard of proof – balance of probabilities; need for particularised evidence of acquisition, development, timing and control. * Admissibility – affidavits by authorized officers relying on investigation files not automatically hearsay. * Third‑party titles – cannot be forfeited absent proof of respondent’s control or beneficial interest. * Jurisdiction – pending review at Court of Appeal does not preclude High Court post‑conviction forfeiture proceedings.
30 June 2023
Prosecution failed to prove trafficking where key witnesses were absent and an uncautioned oral confession lacked corroboration.
* Narcotic drugs – trafficking – burden of proof beyond reasonable doubt; quality of evidence over number of witnesses. * Non‑production of key witnesses – adverse inference where absent witnesses could have supplied decisive evidence. * Oral confession to police – requirement of cautioning and need for corroboration; received with great caution. * Chain of custody/possession – need to prove accused drove or had control of vehicle (driving licence, ownership).
13 June 2023
Court convicted accused of trafficking, finding lawful searches, proven possession and sufficient chain of custody.
Criminal law – narcotic drugs – search and seizure under Cr.P.C. s.38 and DCEA s.32(5); possession and constructive possession; chain of custody – oral proof versus documentary paper trail; alibi—statutory notice requirements (Cap.200 s.42); role and significance of independent witnesses; admissibility and weight of exhibits (certificates of seizure, laboratory analysis).
7 June 2023
March 2023
Court held it was functus officio regarding a previously restored vehicle and struck that vehicle from the forfeiture application.
* Criminal procedure – forfeiture of property – effect of prior judicial determination and withdrawal of appeal – functus officio/issue estoppel. * Civil procedure – preliminary objections – evaluation of affidavit defects at preliminary stage versus merits. * Proceeds of Crime/Drugs legislation – limits to court’s jurisdiction where property previously restored by court order.
17 March 2023
Khat found but seizure and chain-of-custody defects raised reasonable doubt, leading to acquittal and return of the vehicle.
* Drugs law – identification of seized substance – expert forensic analysis established khat (cathine/cathinone) weighing 51.89kg. * Criminal procedure – search and seizure – seizure irregular where certificate signed by persons who did not witness opening and procedures moved from scene to police station. * Evidence – chain of custody – missing handlers and unexplained transfers broke the chain, raising reasonable doubt of tampering. * Possession – knowledge and control – prosecution failed to prove accused knew of or controlled the contraband. * Remedy – acquittal and return of vehicle where prosecution fails to prove case beyond reasonable doubt.
3 March 2023
January 2023
27 January 2023