High Court Corruption and Economic Crimes Division - 2024

49 judgments
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49 judgments
Citation
Judgment date
December 2024
23 December 2024
Prosecution proved 983.5g heroin trafficking; two accused convicted and sentenced to life, third acquitted.
* Drug offences – Trafficking – Proof that seized substance is narcotic (Government Chemist report confirming 983.5g heroin). * Chain of custody – combination of documentary record and credible oral testimony sufficient to preserve exhibit integrity. * Possession – actual/constructive possession and control as element of trafficking; passenger-to-carrier transfer linking accused to drugs. * Burden and standard of proof – prosecution must prove guilt beyond reasonable doubt; accused not required to prove innocence. * Vicarious/knowledge liability – mere carriage as a boda-boda rider without evidence of knowledge does not ground conviction.
17 December 2024
Citation of an incorrect committal provision is curable where substantive compliance with CECD Rules occurred.
* Procedure — Committal proceedings — Whether mis‑citation of Criminal Procedure Act s.246 instead of CECD Rules r.8 renders committal void — Curable irregularity. * Statutory interpretation — EOCCA s.28 and s.30 read with CECD Rules r.8. * Criminal Procedure — Section 4A (amendment) — courts may cure procedural defects to uphold substantive justice. * Remedy — Nullification and recommittal unnecessary where substantive compliance achieved.
13 December 2024
Forensic proof of seized cannabis did not establish the accused’s possession; acquitted for lack of knowledge and control.
* Drug trafficking – possession as element of trafficking – requirement of knowledge and control for actual or constructive possession. * Criminal burden of proof – prosecution must prove possession beyond reasonable doubt. * Credibility of witnesses – contradictions about access to locked room undermined prosecution case. * Forensic evidence and chain of custody establish nature of exhibit but do not by themselves prove accused’s possession.
13 December 2024
First accused convicted and sentenced to life for trafficking >978g heroin; second accused acquitted for lack of proof.
* Criminal law – Drugs – Trafficking in narcotic drugs (heroin) – elements: possession/control and weight threshold (>200g). * Search and seizure – emergency search under Criminal Procedure Act s.42(1)(b) – certificate of seizure admissibility. * Evidence – forensic chemical analysis by Government Chemist as conclusive evidence (Drugs Act s.48A(2)). * Chain of custody – documentation and custody transfers to establish integrity of exhibit. * Standard of proof – prosecution must establish trafficking beyond reasonable doubt; conviction of first accused, acquittal of second.
13 December 2024
10 December 2024
Failure to comply with cautioning, witness and disposal procedures led to acquittal for alleged cannabis trafficking.
Criminal law – Drug trafficking – Proof beyond reasonable doubt; Evidence – oral confession and statutory cautioning; Search and seizure – requirement for independent witnesses; Disposal of perishable exhibits – compliance with section 36, right to be heard, inventory and weighing procedures; Chain of custody and admissibility of destroyed exhibits.
6 December 2024
Irregular disposal, sampling and witness omissions undermined proof; accused acquitted for failure to prove trafficking beyond reasonable doubt.
* Criminal law – Drug offences – Trafficking in narcotic drugs – Statutory disposal, sampling and photographic procedures under section 36 DCE Act must be strictly followed. * Evidence – Corpus destroyed pre-trial – disposal irregularities and lack of magistrate presence undermine admissibility and weight of inventory, photographs and samples. * Procedure – Requirement to record accused’s objections when seeking disposal. * Search and seizure – Need for independent witness and proper cautioning/statutory safeguards under DCE Act and CPA. * Failure to call key witnesses weakens prosecution’s link between accused and seized drugs.
6 December 2024
Court granted ex-parte restraint on vehicles found to be tainted and connected to alleged narcotic trafficking by the respondent.
* Proceeds of Crime Act (POCA) – s.38(1) and s.39(3) – ex-parte restraining orders on property pending prosecution; * Definition of 'tainted property' – s.3 POCA – vehicles as instrumentalities of narcotic trafficking; * Narcotic trafficking – serious offence attracting life imprisonment under DCEA/EOCCA; * Restraint on public officers (TRA) from effecting disposition/transfer of alleged tainted assets.
4 December 2024
November 2024
A prior acquittal on a different document did not bar prosecution for alleged forgery of distinct minutes; plea dismissed.
Criminal procedure – autrefois acquit (Section 137 CPA) – requirements: same accused, same or substantially same issue, final determination by competent court – distinction between different documents (Extract Resolution vs. Minutes) defeats plea – addition of new accused does not bar plea.
29 November 2024
An applicant for extension under POCA must prove good cause and account for every day of delay.
POCA s9(5) – extension of time to file forfeiture application; "good cause" – must be shown and is dependent on circumstances; applicant must account for each day of delay; pendency of appeal by the accused not automatically good cause where appeals were initiated by accused; prejudice not considered if not pleaded.
25 November 2024
Electronic bank statements must be properly authenticated and identified before admission; failure to do so renders them inadmissible.
Evidence — Electronic evidence and banker’s books; committal procedures — Rule 8(2) GN No. 267/2016 and s246(2) CPA; service of committal record — Rule 9 GN No. 267/2016; Evidence Act ss76–79 (banker’s book entries); authentication/identification and chain of custody requirements for exhibits; exclusion for failure to authenticate.
22 November 2024
October 2024
24 October 2024
Prosecution proved trafficking of 275 kg cannabis; accused convicted and sentenced to mandatory life imprisonment.
* Criminal law – Narcotic drugs trafficking – proof beyond reasonable doubt – seizure, laboratory confirmation and chain of custody. * Evidence – Expert (chemist) report admissibility and conclusiveness under Drugs Act. * Procedure – lawful disposal of perishable exhibits and accused’s right to be heard. * Defence – alibi requirements and failure to notify particulars under EOCCA.
18 October 2024
Prosecution failed to prove trafficking due to lack of proof of ownership, control, independent witness and proper disposal procedure.
Drugs — Offence of trafficking — information need not specify mode where type and weight are given; Search and seizure — requirement for witness to be independent or justified exception; Ownership/control of premises — must be proved by independent or corroborative evidence; Disposal of exhibits — accused must be afforded right to be heard and magistrate's oral evidence may be necessary when Form is silent; Proof beyond reasonable doubt — shortcomings in ownership, custody and disposal vitiate prosecution case.
18 October 2024
Accused acquitted because broken chain of custody and defective disposal records prevented proof of drug trafficking.
* Criminal law – Drug trafficking – Proof beyond reasonable doubt – necessity of unbroken chain of custody linking seized items to analysed samples. * Evidence – Chain of custody – contradictions in packaging, labelling and handover times undermine evidential value. * Drugs Act – Disposal and destruction procedures – requirement to record disposal order and net weights after sampling; inventory as primary evidence. * Criminal procedure – Alibi – statutory notice/particulars required; late or unparticularized alibi may be treated as afterthought. * Property forfeiture – Confiscation of vehicle under section 49A(1) Drugs Act where ownership not established.
17 October 2024
Prosecution failed to prove the accused owned or controlled premises where seized drugs were found; accused acquitted.
* Criminal law – Narcotics trafficking – Burden to prove ownership and control of premises where drugs seized; * Search and seizure – Requirement for independent witness to DCEA search and exceptions to police as witness; * Chain of custody and forensic confirmation insufficient where ownership/control not established; * Reasonable doubt arising from custody period and potential third‑party access.
17 October 2024
Acquittal where prosecution failed to prove knowledge/possession and disposal of perishable exhibits violated right to be heard.
* Criminal law – possession and knowledge – actual vs constructive possession – driver of vehicle not automatically in possession of concealed narcotics; prosecution must prove knowledge/control. * Evidence – failure to call key witnesses – adverse inference where unexplained absence, but gaps may still undermine prosecution case. * Evidence/procedure – disposal of perishable exhibits – accused must be present and heard before disposal; flawed disposal renders inventory inadmissible as substitute for physical exhibits.
16 October 2024
Court convicts three accused for trafficking 29.86 kg heroin (life imprisonment); acquits others and orders exhibit disposal.
Criminal law – Drug trafficking – sufficiency of charge particulars; small quantity cannabis vs trafficking; admissibility and weight of Government Chemist report; voluntariness and admissibility of cautioned/oral confessions; constructive possession and joint liability; lawful search in exigent circumstances; chain of custody for narcotics; mandatory life sentence for large-quantity heroin trafficking.
4 October 2024
September 2024
Accused acquitted: material variance in charged location and insufficient evidence of possession/control defeated prosecution.
Criminal law — narcotics trafficking — variance between information and evidence as to place of offence — material discrepancy fatal if unamended; proof of trafficking requires evidence of possession, control or other act; adverse inference where prosecution omits available key witnesses or material exhibits (CCTV, keys).
20 September 2024
Court convicted accused of conspiracy and participation in terrorist meetings but acquitted them of recruitment and financing counts.
* Criminal law – Terrorism offences – conspiracy to commit terrorist acts; participation in meetings relating to terrorism. * Evidence – Admissibility and weight of cautioned statements; trial‑within‑trial procedure and corroboration by independent witnesses. * Evidence – Insufficiency of proof for recruitment and terrorist financing where no traceable transactions or weapons recovered. * Procedure – Alibi defence must be notified; failure to cross‑examine weakens defence case. * Sentencing – concurrent lengthy terms with credit for pre‑trial detention; juvenile treated by probation.
20 September 2024
Chemist's report and adequate chain of custody proved the accused's trafficking; seeds excluded so second count fails.
Drug offences – trafficking in cannabis sativa – Gov’t chemist report admissible and conclusive under statute – chain of custody assessed and upheld despite personnel change – seeds excluded from definition of cannabis; only leaves sustain conviction – evidential weight of police testimony.
13 September 2024
Acquittal where prosecution failed to prove forgery, uttering, money laundering and organised crime due to evidentiary gaps.
Criminal law – Forgery: proof requires showing a false document made with intent to defraud; contradictions and missing documentary proof fatally undermine such charges; Uttering false documents depends on proved falsity; Money laundering convictions require a proved predicate offence and proof of illicit proceeds; Failure to call material witnesses and to produce key documents permits adverse inferences; Prosecutorial discretion may attract criticism where charging decisions create apparent double standards; Caution when convicting on co-accused/interest-driven testimony.
13 September 2024
11 September 2024
Court granted POCA-based restraint orders over cash and vehicle as tainted proceeds and instrumentality of alleged illegal mineral trading.
Proceeds of Crime Act — s38(1) restraint orders; s39(3) pre-conviction conditions (reasonable grounds and tainted property); alleged proceeds and instrumentalities of illegal mineral trading; interim preservation — deposit into Special Interim Management Account; prohibition on transfer and custody of vehicle.
2 September 2024
August 2024
30 August 2024
Court granted ex-parte restraining order preventing disposal of allegedly tainted properties pending appeal under POCA and DCEA.
* POCA s38(1) – ex-parte restraining orders – Director of Public Prosecutions' power to seek restraint of property of persons convicted of serious offences. * Definition of "serious offence" – trafficking in narcotic drugs qualifies under POCA s3. * DCEA s49(4) – presumption that property acquired within ten years before charge may be proceeds of crime. * POCA s39(4) – conditions for issuing restraining orders upon conviction; risk of dissipation pending appeal. * Interim directions to land registry and local government to prevent disposition of potentially tainted property.
21 August 2024
Court granted a restraining order over a house alleged to be proceeds of narcotics trafficking based on seizure and analyst reports.
Proceeds of Crime Act — restraining orders (s.38(1), s.39(3)); tainted property — proceeds of narcotics trafficking; admissibility of seizure certificates and Government Chemist Analyst Report as grounds for restraint; jurisdiction of Corruption and Economic Crimes Division over DCEA/EOCCA offences.
12 August 2024
6 August 2024
June 2024
Court granted an ex parte restraint order against the respondent’s property as allegedly tainted proceeds of crime.
Proceeds of Crime Act — restraint orders (s38(1)) — requirements where respondent unconvicted (s39(3): reasonable grounds to believe offence committed; property tainted/derived from offence) — ex parte application — alleged misappropriation, forgery and money laundering; injunction against disposition of property.
28 June 2024
Accused acquitted where chemist confirmed heroin but search lacked a credible independent witness, undermining lawful seizure.
* Criminal law – narcotic drugs – trafficking under s.15(1)(a) DCE Act and classification under EOCCA First Schedule. * Jurisdiction – consent for economic offences – consent must cite provision creating offence; omission of quantity provision not necessarily fatal. * Evidence – Government Chemist analyst report conclusive on composition and weight. * Search and seizure – statutory requirement for independent witness; credibility and production of independent witnesses material to admissibility. * Burden of proof – prosecution must prove possession and lawfulness of seizure beyond reasonable doubt.
25 June 2024
21 June 2024
Accused convicted for trafficking 213.05 kg cannabis; search, disposal and custody found lawful; mandatory life sentence.
* Criminal law – Drug trafficking – Elements: possession/trafficking and quantity threshold (over 100 kg). * Evidence – Analyst report admissibility and conclusiveness under Drugs Act s.48A(2). * Procedure – Disposal of narcotics under Drugs Act s.36; inventory and magistrate's order. * Search and seizure – exigent circumstances may justify no warrant or independent witness. * Chain of custody – documentary trail and oral testimony can establish continuity of custody. * Defence procedure – failure to comply with alibi notice and lack of cross-examination undermining defence.
13 June 2024
Prosecution proved trafficking beyond reasonable doubt; accused convicted and sentenced to life imprisonment; exhibits ordered destroyed.
* Criminal law – Drug trafficking – Elements of trafficking under Drug Control and Enforcement Act and EOCCA – proof of possession/transportation. * Evidence – Admissibility and conclusiveness of Government Chemist's analyst report (s.48A(2) Drug Act). * Evidence – Chain of custody – preservation through oral testimony and exhibit registers; minor documentary omissions not fatal. * Procedure – Failure to give notice for tendering an exhibit (trailer tank) – irregular admission held harmless where other evidence proves the fact. * Defence – Alibi requirements under section 42 EOCCA – failure to notify and consequences. * Sentence – Statutory maximum (life imprisonment) for trafficking large quantities of cannabis.
13 June 2024
May 2024
20 May 2024
13 May 2024
Accused convicted and sentenced to life for trafficking 4.14 kg heroin; urgent search and chain of custody upheld.
Drug offence — Trafficking — Proof of composition and weight — Government Chemist analysis; Search and seizure — emergency/urgency exception to warrant requirement; Seizure documentation — evidential weight of certificate vs oral testimony; Chain of custody — acceptable by combination of paper trail and oral evidence; Alibi — late disclosure and court's discretion to disregard; Sampling sufficiency — GCLA procedures govern samples; Labeling — acceptable when performed by authorized officers at ADU.
10 May 2024
April 2024
29 April 2024
Accused acquitted where defects in search, absence of independent witness and broken chain of custody undermined prosecution's drug case.
Criminal law – Drug trafficking – proof beyond reasonable doubt; Search and seizure – warrant exceptions and need for independent witness and seizure receipt; Chain of custody – requirement for unimpeachable continuity of exhibits; Government Chemist report – evidential weight where procedural prerequisites satisfied; Impact of procedural defects on admissibility and reliability of exhibits.
5 April 2024
March 2024
Accused convicted of heroin trafficking; search, seizure and chain of custody upheld; each sentenced to 30 years.
* Criminal law – Narcotic trafficking – Proof by expert chemical analysis – Meckel reagent, SPE and LCMS confirm heroin hydrochloride. * Criminal procedure – Search and seizure at airport – emergency search and certificates of seizure; independent witness requirement. * Evidence – Chain of custody – oral testimony and handing-over documents sufficient to maintain integrity of exhibits. * Procedural fairness – omission of a witness in committal not fatal where statement was available and no prejudice shown. * Regulatory compliance – sample size under Regulation 17 disputed but not fatal to lab conclusions.
28 March 2024
Visual identification, intact chain of custody and ownership evidence supported the accused's trafficking conviction.
Criminal law – Trafficking in narcotic drugs – Chemical analysis confirming cannabis sativa; Evidence – Chain of custody – proper seizure, labeling and exhibits register; Identification – visual identification and identification parade reliability; Ownership – sale agreements and bank slips linking accused to vehicle; Alibi – late notice and inadequate particulars; Preliminary hearing – witnesses admitted though not listed at PH.
15 March 2024
Conviction for trafficking in 113.49 kg cannabis; emergency warrantless search upheld, 25-year sentence, drugs destroyed, vehicle released.
* Criminal law – Trafficking in narcotic drugs – proof beyond reasonable doubt – chemical analysis confirming 113.49 kg cannabis sativa. * Criminal procedure – Search and seizure – emergency search without warrant under section 42(1)(b)(ii) CPA. * Evidence – chain of custody and witness credibility – admissibility and integrity of exhibits. * Sentencing – statutory minimum and aggravating factors; destruction of exhibits; release of vehicle to registered owner.
1 March 2024
Court convicted both accused of trafficking cannabis after drugs, lawful seizure and intact chain of custody were proved beyond reasonable doubt.
Drugs Control Act — trafficking — identification of narcotic substance by chemist; search and seizure — seizure certificate and independent witness; chain of custody — occurrence book and exhibits register; admissibility and weight of oral admissions; late alibi — failure to give notice under CPA; sentence for narcotic trafficking.
1 March 2024
Court convicted both accused of trafficking 136.55 kg cannabis, upheld search/chain-of-custody and sentenced each to 25 years.
* Drugs — Trafficking — Whether seized 8 sacks constituted narcotic drug (Cannabis sativa) — Expert analysis and weight (136.55 kg). * Evidence — Search and seizure — Compliance with statutory procedure; seizure certificate and independent witness. * Evidence — Chain of custody — Occurrence book, exhibit register, DCEA forms and continuity of possession. * Evidence — Oral admissions/confessions — Weight and caution in assessing admissions given to investigating officers. * Criminal procedure — Defence of alibi — Requirement to give notice and opportunity to cross-examine prosecution witnesses. * Sentence — Severe statutory regime for trafficking — 25 years imprisonment imposed.
1 March 2024
February 2024
21 February 2024
9 February 2024
6 February 2024
5 February 2024
5 February 2024