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.

36 judgments
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36 judgments
Citation
Judgment date
December 2010
High Court lacked jurisdiction to order possession while a cross‑appeal affecting the property remained pending at the Court of Appeal.
Civil procedure – Execution – Third‑party purchaser’s application for delivery of possession where cross‑appeal is pending; Appeal law – Cross‑appeal survives striking out of principal appeal and requires express Court of Appeal order to end it; Court of Appeal Rules – Notice to withdraw cross‑appeal (Rule 104(1)) does not automatically terminate cross‑appeal; Execution – appeal/cross‑appeal does not automatically stay execution absent express stay order; Fraud allegations in execution require higher, specific proof.
24 December 2010
Enforcement of guarantee not barred as res sub judice nor abuse of process absent identity of issues.
* Civil Procedure Code s.8 (res sub judice) – requires identity of matters directly and substantially in issue before stay applies. * Res judicata (s.9) – final decision operates as bar only where issues are identical. * Abuse of process – not a preliminary point of law if facts/evidence required (Mukisa test). * Remedy for res sub judice is stay, not necessarily dismissal. * Pleading requirements – allegations of fraud or non‑compliance elsewhere cannot be resolved on preliminary objection without evidence.
21 December 2010
The applicant proved a valid board resolution and breach by the bank, but failed to prove quantifiable damages.
Banking law – change of signatories – corporate authority and mandate – Companies Act s.181/s.191(1) – duty of banker to act on valid instructions – withholding of security after loan repayment – proof of damages (need for financial records to quantify loss).
20 December 2010
Taxing master may exceed the outdated tariff; bill of costs taxed at Tshs.7,188,345 after adjustments.
Taxation of costs – ability to depart from GN.515/91 scale – factors for departure (amount, complexity, time, research, party conduct) – instruction fees – attendance fees – duplication (pleadings included in instruction fee) – disbursements – proof of VAT registration.
15 December 2010
Ex parte judgment awarding agreed refund and interest where seller breached refund-and-return agreement after non-delivery.
Commercial law – Sale of goods – Failure to deliver – Agreement to discharge obligations – Ex parte proof after substituted service – Award of agreed refund with interest and costs.
15 December 2010
A preliminary objection on lack of locus standi fails where the issue involves mixed facts requiring trial evidence.
* Civil procedure – Preliminary objection – Locus standi – Whether absence from a lease agreement precludes standing where commercial relationship or interest is alleged – Mixed questions of fact and law require evidence at trial and cannot generally be disposed of by preliminary objection (Mukisa principle applied).
14 December 2010
Execution permitted to proceed subject to a prior registered debenture; reservation of title excluded specific asset from attachment.
Order XXI, Rule 57 — objection to attachment; Debenture/floating charge — validity and priority; Companies Act s.96–97 and Stamp Duty — registration/stamping of charges; Reservation of title — exclusion from attachment; Garnishee order compliance; Court's discretion under Rule 61 to continue execution subject to prior charge.
13 December 2010
Court found an implied principal–agent relationship and awarded plaintiff proven invoice amount, interest and costs.
* Contract law – principal and agent – implied agency inferred from conduct and course of dealing (Law of Contract Act ss.134, 139). * Evidence – commercial invoices and shipping documents as sufficient proof of delivery and debt. * Remedies – assessment of proved quantum, pre- and post-judgment interest and costs.
8 December 2010
November 2010
Court dismissed preliminary objections, holding extension application properly brought, not frivolous, and not barred by limitation.
Civil procedure – extension of time – section 14(1) Law of Limitation Act; section 93 Civil Procedure Code; Order XLIII Rule 2 (procedure for applications) – oral applications; frivolous/vexatious proceedings – abuse of process; time-barred applications – exercise of court’s discretion to extend time; High Court’s inability to revise its own interlocutory decisions.
16 November 2010
Leave to defend a summary suit granted where the defendant genuinely disputes indebtedness and stopped payment on post‑dated cheques.
Summary suit — leave to appear and defend — post‑dated cheque and stop payment — existence of triable issue — defendant entitled to explain stopped payment; conditions for leave (triable issue, non‑sham defence) apply.
11 November 2010
A filed notice of appeal generally divests the High Court of jurisdiction to grant stay of execution; application dismissed with costs.
Appeal pending — filing of notice of appeal divests High Court of jurisdiction to grant stay of execution or related relief except in limited statutory exceptions; Order IX Rule 8 CPC — non-appearance by plaintiff/applicant — ex parte hearing and dismissal; Certificate of urgency — does not excuse non-appearance.
5 November 2010
Review dismissed: review jurisdiction is limited; alleged procedural defects and fraud are not errors apparent on the face of the record.
* Civil procedure – Review under Order XLII Rule 1 CPC – limited to errors apparent on face of record, new evidence or other sufficient reasons; not an appeal in disguise. * Default judgment – grounds for review versus appeal – procedural complaints (service, extension of time) are typically matters for appeal, not review. * Allegations of fraud and collusion – require extraneous evidence and extended inquiry, not errors apparent on record. * Locus standi/interested party – status of applicants as administrators considered but not determinative of review jurisdiction.
2 November 2010
October 2010
Plaintiff's suit dismissed for failing to plead a cause of action where plaintiff owed money and alleged harms were inadequately pleaded.
Civil procedure – Preliminary objection – Pleadings must disclose cause of action – Order VII r.1(e) & r.11(a) – Cause of action requires antecedent legal right, corresponding duty, breach and damage – Insufficiently pleaded reputational loss.
27 October 2010
Rule 87(1) deposits are jurisdictional; omnibus applications are permissible; non‑deposit renders setting‑aside application incompetent.
Civil procedure – Execution of decrees – Order XXI Rule 87(1) – Setting aside sale in execution – Requirement to deposit five percent of purchase money and decretal sum as condition precedent – Jurisdictional effect of non‑compliance; Omnibus Chamber Summons – combining extension of time and setting aside application permitted when prayers are related.
20 October 2010
Failure to deposit sums required by Order XXI Rule 87(1) renders an application to set aside a sale incompetent.
Civil procedure – execution of decree – Order XXI Rule 87(1) – application to set aside sale – deposit of 5% of purchase price and decretal amount as condition precedent to jurisdiction – omnibus applications permissible where prayers are connected.
20 October 2010
Taxing officer may increase instruction fee above prescribed scale, but must do so judicially; bill taxed at Tsh 2,599,000.
Costs – Taxation of a bill of costs; instruction fee – discretion to depart from prescribed scale (Schedule XI j(i)); public corporations represented by officers taxed like private advocates; attendance and disbursement rates; reliance on precedent (MGS International case).
19 October 2010
Execution ordered where debtors failed to show cause; unproven, belated fraud allegations by guarantors dismissed.
* Civil procedure – execution of decree – Order XXI Rule 21(1) – court must order execution where person fails to show cause to satisfaction of court. * Debt enforcement – instalment requests – previous unsuccessful applications and dilatory conduct do not justify further stay of execution. * Fraud allegations – must be pleaded and strictly proved; burden lies on those alleging fraud; raising fraud at execution stage is improper. * Security – defects in some securities do not invalidate other valid securities or the loan agreement as a whole.
18 October 2010
Plaintiff’s suit struck out for lapse of Speed Track III 14-month life-span without timely extension or departure application.
Civil Procedure — Order VIII A, Rule 3(3)(c) — Speed Track 3 (14-month life-span) — computation of life-span — requirement to apply for extension/departure before expiry — failure to apply permits striking out — late application not entertained after objection.
4 October 2010
E‑mails are potentially admissible as "documents" if relevance, authentication, hearsay, originality and prejudice standards are satisfied.
Electronic evidence – admissibility of e-mails in civil proceedings – Interpretation of "document" under Evidence Act to include electronically stored information – Required standards: relevance; authenticity (audit trail/process); hearsay analysis; original-writing/best-evidence rule; probative value vs unfair prejudice – Court-developed guidance pending legislative detail.
1 October 2010
September 2010
Bill of lading not conclusive of ownership; purchaser in transit entitled to release of cargo and awarded TZS 10,000,000 loss of profit.
Commercial law – bills of lading as documents of title – not conclusive proof of ownership; sale in transit; terminal/depot operators’ limited powers under Customs Act; entitlement to delivery upon customs release; assessment of loss of profits and interest.
30 September 2010
Failure to act within a court‑granted extension rendered the application for leave to seek prerogative orders time‑barred.
Limitation law – prerogative orders – extension of time – effect of earlier court‑granted extension – striking out for prematurity – procedural requirement to apply for leave before substantive prerogative application.
24 September 2010
Applicant awarded repayment and interest after respondent breached contract to install ferry ticketing machines.
* Contract law – supply and installation of equipment – formation and terms – proof by contract and payment vouchers. * Breach of contract – delay and non-performance (failure to hand over, provide warranty/spare parts, training, radio link). * Civil procedure – substituted service and ex parte proceedings where respondent not served/responding. * Damages – refusal to award general damages where claimant’s evidence is general and unquantified. * Remedies – restitution of payments and high pre-judgment interest plus costs.
24 September 2010
Reported
19 September 2010
Preliminary objections alleging no cause of action or limitation fail when they raise factual, not self‑proving legal, issues.
Preliminary objections — competence — must be pure points of law and self‑proving; Cause of action — pleaded allegation of unpaid loan discloses cause of action; Limitation/time‑bar — continuous breach raises factual issues not suitable for preliminary determination; Mukisa Biscuits test applied; factual disputes must be tried.
16 September 2010
An incurably defective affidavit answering interrogatories permits striking out the defence and proceeding ex parte under Order XI Rule 18.
Civil procedure – Interrogatories (Order XI) – Answers by affidavit (Rule 7) – Incurably defective affidavit (missing dates on verification/jurat) – Striking out affidavit – Distinction between Order XI Rule 9 (insufficient/omitted answers) and Rule 18 (failure to comply) – Consequence: striking out defence and proceeding ex parte – Procedure for delivering interrogatories (Rules 1 & 2) and responsibility to ensure proper execution.
6 September 2010
August 2010
An unsubstantiated claim of counsel’s illness does not establish sufficient cause to set aside a dismissal for non‑appearance.
Civil procedure – setting aside dismissal under Rule 9(1) CPC – sufficient cause for non‑appearance – illness of counsel – requirement for objective medical evidence – non‑prosecution/laxity by plaintiff.
20 August 2010
Plaintiff proved outstanding contractual debt; awarded principal, 12% monthly contractual interest, 7% post-judgment interest, and costs.
Contract debt – ex parte proof – invoices, delivery notes and statement of account – contractual term for 12% per month on overdue accounts – award of 12% monthly pre-judgment interest and 7% per annum post-judgment interest – general damages not awarded for unproven loss – punitive damages refused where default due to financial difficulty – costs follow the event.
19 August 2010
June 2010
Court allowed departure from scheduling order and extended time, holding Rule 4 directory and inherent powers permit relief to serve justice.
Civil procedure – Scheduling conferences and speed tracks – Order VIII A, Rule 4 – Directory not mandatory – Court’s inherent jurisdiction – Sections 93 and 95 Civil Procedure Code – Extension of time to depart from scheduling order – Limitation and interest of justice.
28 June 2010
High Court lacks jurisdiction over challenge to EWURA Compliance Orders; appeal lies to the Fair Competition Tribunal.
* Jurisdiction – challenge to EWURA Compliance Orders – whether High Court or Fair Competition Tribunal has exclusive jurisdiction. * Administrative law – Compliance Orders under s.39 EWURA Act – effect and attributes of such orders. * Appeals – s.29 EWURA Act and s.52 Petroleum Act – internal review and appeal to the Fair Competition Tribunal. * Enforcement – Compliance Order enforceable as injunction of the High Court but not equated to a High Court order for jurisdictional purposes. * Finality – FCT determinations final and enforceable as High Court orders.
28 June 2010
Preliminary objections involving factual disputes cannot dispose of a section 89(1)–(2) restitution application.
Civil procedure – Preliminary objections – Section 89(1) & (2) CPC (restitution) – Whether objections raise pure points of law or require merits/factual inquiry – Pending related proceedings do not automatically oust jurisdiction to hear restitution application.
22 June 2010
Whether the extension application was time‑barred and affidavit defects warranted dismissal; Court struck application out for lack of good reasons.
Appellate procedure – extension of time under s.11 Appellate Jurisdiction Act – Rule 76 Court of Appeal Rules; Limitation Act s.43(b) – clause 21 inapplicable to appeals; preliminary objections – scope and limitation; affidavits – facts vs. argument, verification by advocate curable; exercise of judicial discretion requires good reasons for delay.
14 June 2010
May 2010
Extension of time granted where appeal was struck out due to a defective decree caused by court error.
Appellate procedure – Extension of time under section 11(1) Appellate Jurisdiction Act; defective decree (date discrepancy) – error of court as sufficient reason; appeals struck out – remedy to revive appeal by curing decree; discretion of High Court to extend time exercised justly.
11 May 2010
Preliminary objections on lack of board resolution, verification wording, and attestation were dismissed as evidentiary, not pure, points of law.
* Company law – requirement of Board resolution to institute proceedings – judge‑made rule; * Civil procedure – preliminary objection – pure point of law test (Mukisa) and when evidentiary issues defeat summary disposal; * Pleadings – Order VI Rule 15 verification requirements — omission curable by amendment; * Contract law – attestation/signature disputes are evidentiary, not suitable for preliminary determination.
6 May 2010
April 2010
Pleadings disclosing a contract and its alleged breach suffice to defeat preliminary objections on cause of action and locus standi.
Cause of action — sufficiency of pleadings — court at preliminary objection stage confined to four corners of the plaint and annexures; locus standi dependent on existence of pleaded cause of action; merits and evidence reserved for trial.
16 April 2010
March 2010
Dispute over exercise of power of sale of mortgaged property falls within Land Division's exclusive jurisdiction; suit struck out.
Land law – Exclusive jurisdiction of the Land Division over mortgage sale and possession actions; Mortgage Financing (Special Provisions) Act 2008 s18(2)-(3) – action to exercise power of sale is a land matter; s18(3) transfer provisions apply only where action is filed in a forum other than the High Court; Commercial Division lacks jurisdiction; suit struck out with costs.
16 March 2010
January 2010
Reported
Court held e‑mails can be "documents" and set five evidentiary hurdles for admissibility of electronic evidence in civil trials.
Electronic evidence — admissibility of e‑mails in civil proceedings — meaning of "document" under Evidence Act — authentication of ESI — hearsay, best‑evidence rule, relevance and probative value versus prejudice — judicial development of admissibility standards.
10 January 2010