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.

20 judgments
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20 judgments
Citation
Judgment date
December 2009
The applicant's suit for prerogative orders was struck out for failing to obtain the mandatory leave to apply.
* Prerogative remedies – Certiorari, Mandamus, Prohibition – prerequisite of leave before substantive application – non-compliance renders application premature and defective.* Procedural law – substantive requirement versus technicality – leave requirement is substantive and mandatory.* Judicial review procedure – failure to follow leave requirement justifies striking out application with costs.
14 December 2009
November 2009
A valid Tanzanian trade mark registration grants exclusive territorial rights; prior use or foreign registration must be proven.
Trade marks — Registration validity — Territoriality of trade mark rights — Proof of prior use — Agency/authorization inconsistencies — Injunctive relief granted; damages and accounting denied for lack of evidence.
13 November 2009
Court granted interim injunction restraining regulator from allocating disputed spectrum pending trial.
Telecommunications law – Spectrum allocation and Application Service Licences; Interim injunction – preservation of status quo; Injunction tests – prima facie case/serious issues, irreparable harm, balance of convenience; Procedural objection – compliance with Order XIX r.3 CPC; Evidentiary weight of admissions and documentary communications (24 April 2007 letter).
3 November 2009
The Commercial Division has jurisdiction over company governance disputes; preliminary objections to jurisdiction and frivolousness were dismissed.
* Commercial jurisdiction – company governance disputes – Commercial Division jurisdiction under High Court Registries Rules and Companies Act. * Civil Procedure – Order VII r.1(i) (value of subject matter) – applicability limited to cases where monetary valuation is possible; Commercial Court (Fees) Rules govern commercial claims. * Cause of action – misappropriation and breach of duty by company officers sufficient under Companies Act. * Civil procedure – objections of frivolousness, abuse of process and multiplicity of causes dismissed where claims relate to company management.
2 November 2009
October 2009
The court dismissed preliminary objections, allowing the suit concerning an adjudicator’s decision to proceed on its merits.
Civil Procedure – Preliminary objections – Cause of action, res judicata, party joinder, and procedural defects.
23 October 2009
Applicant awarded container replacement cost; detention, clearing charge and general damages not proved; interest reduced.
Commercial law – clearing and forwarding – claims for demurrage/detention, replacement and clearing charges; burden of proof on claimant; inconsistent invoices undermine claimed sums; general damages require pleading and proof; court reduces excessive interest rates.
23 October 2009
The defendant bank negligently failed to verify account‑opening documents per BoT guidance and is liable for conversion of the plaintiff’s funds.
* Banking law – duty of bank to verify identity, directors and authenticity of company documents when opening accounts – compliance with Bank of Tanzania Circular No. 8 of 2000. * Negligence – banker’s failure to make proper inquiries and follow up referees amounts to negligence; liability for conversion of funds. * Forgery and fraud – third party presenting forged memorandum/articles and false resolution. * Indemnity – bank entitled to be indemnified by fraudulent third party for sums paid to injured customer. * Damages and interest – award of principal, general damages and post‑judgment interest.
22 October 2009
Citing general procedural provisions when specific rules apply renders an interlocutory application incompetent.
* Civil Procedure – Interlocutory relief – Where specific procedural rules (Order XXXVII) apply, general powers under sections 68 and 95 cannot be invoked in their place. * Execution – Sale in execution – Remedy to set aside sale for irregularity located in Order XXI r.88(1). * Procedural competence – Citing wrong enabling provisions renders an application incompetent.
5 October 2009
September 2009
The applicant’s extension application citing the wrong statutory provision was incompetent and struck out with costs.
* Civil procedure – extension of time – enabling provision – omission to cite specific subsection (11(1)) – jurisdictional defect – incompetence. * Amendment of pleadings – chamber summons – formal amendment required; court cannot insert omitted statutory subsection sua sponte. * Dispositive jurisdictional defects obviate need to consider substantive merits (delay, illegality, negligence).
21 September 2009
Commencement of exploration terminates annual anniversary payments under a prospecting assignment; Plaintiff’s claim dismissed.
Contract interpretation – prospecting agreement – Article 3: upfront payment and annual anniversary payments until commencement of exploration or abandonment; commencement of exploration terminates annual payment obligation; contemporaneous notice as evidence.
18 September 2009
Applicant’s claim on disputed accounting failed for lack of independent evidence; uncontroverted June 2004 balance awarded with interest.
Sale of goods – Partly written and implied contract; Evidence – failure to call material independent witnesses (TRA/bank) – adverse inference; Civil Procedure Code, Order XIII – documents not produced/admitted are not part of the record (TZR1 expunged); Counterclaim not proved; Award of uncontroverted balance with interest and costs.
7 September 2009
August 2009
Whether a bank can obtain ex parte judgment enforcing an overdraft secured by a debenture and personal guarantee.
Commercial law – recovery of overdraft – enforcement of registered debenture and charge; personal Guarantee and Indemnity – director’s joint and several liability; ex parte proof where defendants default; award of contractual and post-judgment interest; costs.
10 August 2009
July 2009
High Court lacked pecuniary jurisdiction; joinder of the Attorney General does not automatically confer jurisdiction.
Jurisdiction — pecuniary limits of High Court under Magistrates' Courts Act s40(3); Government Proceedings Act s6(4) — joinder of Attorney General does not confer jurisdiction; Constitutional challenges — procedure under Basic Rights and Duties Enforcement Act; Requirement to notify State under s6(2) of Government Proceedings Act (raised as objection).
3 July 2009
May 2009
Unsigned pleadings are defective under Order VI Rule 14 but are curable by amendment; court ordered advocates to sign within seven days.
Civil procedure — Order VI Rule 14 CPR — Mandatory signature of party and advocate on pleadings — Unsigned pleadings are defective but curable by amendment before judgment — Written statement of defence subject to same requirement.
8 May 2009
Extension of time to appeal refused for lack of material facts and failure to file required written submissions.
* Appellate Jurisdiction Act s.11(1) – extension of time to file notice of appeal – discretionary power requires material facts; * Civil procedure – failure to file written submissions equated to non-appearance; * Rejoinder – inadmissible where no initial submissions exist; * Procedural irregularities – appeals struck out for defective supporting documents.
2 May 2009
April 2009
An established company’s long-used name can bar registration and use of a similar name due to likely passing off and public confusion.
* Company names – similarity and passing off – identity, similarity and likelihood of confusion – long use and reputation may give proprietary effect to a company name. * Registrar powers – refusal/correction of registration where a name would infringe or cause passing off – registrar’s direction to change name proper where oversight occurred. * Remedies – declaratory relief, permanent injunction, striking off name from register, removal of advertisements, costs.
28 April 2009
Applicant failed to discharge burden to set aside security-for-costs order; proof of local assets and authenticated returns was inadequate.
Security for costs – Order XXV r.1(1) – requirement for credible proof of registered office, local immovable property and authenticated annual returns (BRELA); foreign majority shareholders; risk of piercing corporate veil; discretion to refuse setting aside security order.
22 April 2009
March 2009
Court pierced corporate veil, held director jointly liable for dishonoured cheques and awarded principal plus simple commercial interest.
Commercial law – dishonoured cheques; corporate veil – lifting veil to hold director personally liable where company formalities and authorisation not proved; interest – compound interest not awarded absent agreement, simple commercial interest awarded; contract – implied contract by conduct rejected for insufficient evidence; counterclaim dismissed.
23 March 2009
Applicants failed to show good cause; Taxing Master's 3% instruction fee was upheld as not excessive.
Taxation of costs; service and awareness of taxation proceedings; extension of time under s.14 Law of Limitation Act; admissibility and limits of hearsay in affidavits (Order XIX r.3(1)); court's inherent powers under s.95 Civil Procedure Act to review Taxing Master's decisions; interference only for error of principle or manifestly excessive awards; advocate's instruction fee (3%) and discretion of Taxing Master.
3 March 2009
February 2009
Bank unlawfully debited joint accounts to secure a third party loan; lien not proved and bank breached duty, damages awarded.
* Banking law – validity of security over deposits – authenticity of lien instrument and handwriting proof. * Banker–customer duty – duty of care to joint account holders; need to ensure informed consent and independent legal advice when accepting security. * Evidence – admissibility and weight of forensic handwriting reports; official report formalities and chain of command. * Remedies – release of wrongfully debited funds with contractual interest; award of punitive and general damages.
12 February 2009