High Court Commercial Division

The Commercial Court was officially inaugurated on 15th September, 1999. The Government of Tanzania endorsed the recommendations in 1997. It is a division of the High Court of Tanzania. The difference with other High Court Registries is that this court specializes in the determination of commercial disputes only.

26 judgments
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26 judgments
Citation
Judgment date
December 2006
A district court lacked jurisdiction over a commercial insurance claim exceeding Tshs.30,000,000; appeal allowed.
Jurisdiction — point of jurisdiction may be raised at any stage including on appeal; Magistrates Courts Act — definition of "commercial case" and pecuniary limits; District Court lacks jurisdiction in commercial cases exceeding Tshs.30,000,000; uncertain contingent or daily- rate claims cannot be used to fix pecuniary jurisdiction; ex parte judgment void if court lacks jurisdiction.
12 December 2006
Jurisdiction may be raised anytime; District Court lacked jurisdiction over a commercial indemnity claim exceeding Tshs.30,000,000.
Jurisdiction – Issue of jurisdiction can be raised at any stage including on appeal; Magistrates Courts Act s.40(3)(b) – District Courts lack jurisdiction over commercial cases exceeding Tshs.30,000,000; Pecuniary jurisdiction – indeterminate future-dated daily loss claims cannot be used to inflate jurisdictional value; Commercial nature – insurer indemnity claims are commercial matters.
12 December 2006
November 2006
Computer-generated account statements, served on the debtor and responded to, can sustain a claim for unpaid parts and services; claimed subsequent payment credited.
Commercial law – recovery of unpaid invoices – admissibility and probative value of computer-generated account statements without accompanying job cards – Order VII r.2 Civil Procedure Code and sufficiency of plaint – deduction for subsequent payment.
4 November 2006
October 2006
A verification clause missing verifier name, place and date is a curable procedural defect; amendment ordered, not striking out.
Verification clause — defects (absence of verifier’s name, place and date) — Order VI r 15(3) CPC — procedural defect curable by amendment — plaint not to be struck out.
31 October 2006
Stay refused: respondent not party to arbitration clause and applicant had taken steps in the proceedings.
* Arbitration Act s.6 – stay of proceedings – requirements: parties to submission or persons claiming under them, no step taken in proceedings, readiness to arbitrate.* Scope of "person claiming under" – subsidiary/assignee/representative relationship required; independent parties not caught.* "A step in the proceedings" – includes applications to court (e.g., variation, review, interlocutory applications) which bring matter closer to determination.* Inherent jurisdiction/Civil Procedure (Arbitration) Rules – court may refer to arbitration only where parties agree; cannot force arbitration absent agreement.
30 October 2006
Sale to the auctioneer’s employee breached Order 21 rule 71, justifying nullification and re-auction to protect the decree-holder.
Civil Procedure – Execution sale – Order 21 r.71 prohibition on persons with duties in connection with sale bidding; auctioneer’s associate (driver) barred from purchasing. Civil Procedure – Setting aside sale – Order 21 r.88 requires material irregularity/fraud and substantial injury; lower sale price and favouritism satisfy requirement. Public auction – conflict of interest and rule against bias; illegality v. irregularity distinction.
26 October 2006
An unendorsed chamber summons and affidavit do not properly move the court and the application was struck out.
* Advocates Act s.44(1) – endorsement/signature requirement for instruments prepared by advocates. * Civil procedure – validity of chamber summons and affidavit – effect of lack of endorsement. * Court of Appeal authority – need for signature on affidavits to properly move the court. * Costs – no costs where defect raised by court suo motu.
26 October 2006
A decree holder must prove a judgment debtor had means and acted in bad faith before committal to civil prison.
Civil procedure — Execution — Committal to civil prison under s.44(1) and O.XXI r.35/39 — Where debtor appears O.XXI r.39 applies — Decree holder bears burden to prove present ability to pay and bad faith — Dishonoured cheque insufficient without proof of means.
20 October 2006
September 2006
Temporary injunction granted to prevent transfer and removal of factory assets pending determination of the main suit.
Interim injunction — restraining registration/transfer and removal of factory assets pending trial — Atilio v Mbowe principles applied: prima facie case, irreparable harm, balance of convenience — injunction granted.
26 September 2006
Temporary injunction granted for alleged trade mark infringement and passing off due to prima facie case and irreparable goodwill loss.
Interim injunctions; trade mark infringement and passing off; prima facie case; irreparable loss of goodwill; competing trade mark registrations and allegations of bad faith; balance of convenience.
8 September 2006
August 2006
Court granted an interim injunction protecting the applicant’s access to project premises, equipment and documents.
Interim injunction — prima facie case — irreparable harm — balance of convenience — preservation of access to contracted premises, equipment and documentation — application under certificate of urgency (Atilio v Mbowe principles).
28 August 2006
July 2006
Certified prior judicial proceedings may be admitted late where no prejudice is shown and documents are above suspicion.
Civil Procedure — Order XIII Rule 2 — meaning of "good cause"; late production of documents; certified judicial proceedings above suspicion; admission where no prejudice shown; discretion to admit to ensure fair trial.
27 July 2006
June 2006
Judicial review and mandamus denied where applicant failed mandatory bid requirement and Appeals Authority dismissed appeal.
Public procurement — mandatory bid requirements — whether a High Court order can substitute for Manufacturer's Authorisation — judicial review vs. finality of procurement — availability of compensation where Appeals Authority dismisses complaint (s.82(4)(f), s.85 PPA).
30 June 2006
A lower court cannot reopen a Court of Appeal decision and execution requires certified proof of payment.
Civil procedure – Execution of decree – Requirement for affidavit and certification of payment under Order XXI CPC; Functus officio – Lower court cannot reopen matters decided by Court of Appeal; Proper remedy against appellate adjustment is review/revision at appellate court.
20 June 2006
Application dismissed after supporting affidavit was struck out for lacking verification clause and proper jurat.
Affidavit formalities; verification clause and jurat requirements; Notaries Public and Commissioners for Oaths Ordinance s.8; incurably defective affidavit; striking out affidavit; dismissal of unsupported application.
5 June 2006
Suit dismissed with costs where plaintiff failed to deposit security for costs within fixed time and gave no justification for delay.
Security for costs – Order XXV r.2(1) CPC – mandatory deposit within fixed time – late telegraphic transfer without leave insufficient – need for prior application or satisfactory reasons to depart – dismissal with costs.
2 June 2006
Default under a consent judgment permits execution by attachment and sale even if the title was not formally mortgaged.
Execution – attachment and sale of immovable property – Order XXI r.53 Civil Procedure Code – effect of consent judgment and repayment schedule – default under settlement – deposit of title deed as additional security/equitable mortgage – stay of sale refused.
2 June 2006
May 2006
Leave to defend summary suit granted despite unverified counter‑affidavit; defect treated as curable and triable issues found.
Civil procedure – summary suit – leave to appear and defend under Order XXXV; affidavit formalities – verification clause – curable defect; requirement of notice before raising preliminary objection; avoidance of technicalities defeating substantial justice (Article 107A(2)(e)).
23 May 2006
Court found defendant negligent, awarded Tshs.35,215,367 and Tshs.5,000,000; insurer not liable for failure to be timely notified.
* Tort — Negligence — wrongful parking causing collision; criminal conviction under s.43A Evidence Act as evidence of negligence. * Contributory negligence — burden on defendant to prove contributory fault; absent here. * Damages — total loss valuation: use of import/SGS documents, adjustment for currency devaluation and depreciation; special damages must be pleaded and strictly proved. * Insurance — existence of cover note/estoppel; insurer’s liability depends on notice and policy terms; failure to notify claimant’s loss can relieve insurer of indemnity.
12 May 2006
April 2006
Occupier's failure to justify continued possession warranted court-ordered eviction to give vacant possession to purchaser.
Eviction — Occupier's burden to show reasons to resist eviction — Failure to justify continued occupation — Order for eviction to give vacant possession to purchaser — Immediate effect.
25 April 2006
March 2006
Allegations of non‑disclosure or alteration of insured risk are factual and must be tried, not resolved as preliminary points of law.
* Civil procedure – preliminary objections – must raise pure points of law and cannot depend on disputed facts requiring trial evidence. * Insurance law – non-disclosure and material alteration of risk – factual issues not suitable for determination as preliminary points of law. * Procedural requirement – no obligation to cite a specific statute for a preliminary objection, but the objection must still be a pure point of law.
28 March 2006
February 2006
15 February 2006
A continuing breach under section 7 restarts limitation, so the contractual claim was not time-barred.
Limitation law – Law of Limitation Act 1971 – section 7 (continuing breach) – accrual of cause of action – section 4 and 5 applicability after repudiation – contractual claims and tolling by negotiations/promises.
13 February 2006
Defective verification is curable; absence of board-authorisation is not resolvable by preliminary objection.
Civil procedure – Pleadings – Verification of plaint – omnibus verification defective for failure to distinguish paragraphs true to knowledge or belief, lack of date/place and signatory titles – Order VI r.15; Curable defects – court’s duty to do substantive justice allows amendment; Preliminary objections – scope per Mukisa Biscuits test – matter requiring evidence (board resolution) not suitable as preliminary objection; Cause of action – sufficiency of plaint and annexures to show cause of action.
9 February 2006
Appointment of a receiver after the defence deadline does not allow late extension; suit proceeds ex parte against that defendant.
Civil procedure – Default – Effect of appointment of receiver/manager after expiry of time to file defence – O. VIII r.2 Civil Procedure Code (as amended by GN 422/94) – Receiver not a party unless joined – No power to extend time where period has lapsed.
3 February 2006
January 2006
4 January 2006