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.

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176 judgments
Citation
Judgment date
December 2016
Applicant's concession to a preliminary objection led to striking out with costs; counsel's oversight not a sufficient excuse.
Commercial procedure — costs follow the event; s.30(2) Civil Procedure Code — written reasons required to deny costs; counsel's oversight not a sufficient ground to deprive successful party of costs; compliance with rule 64 (counter-affidavit and skeleton arguments) justifies costs; application struck out with costs.
22 December 2016
Court upheld Taxing Officer’s discretion but reduced an excessive per‑item travel allowance and expunged late rejoinder.
Costs — Taxation — Advocates' Remuneration and Taxation of Costs Rules (1991) applicable where bill filed before repeal; rule 46 (one‑sixth) concerns costs of taxation only; rule 55(1) requires receipts but Taxing Officer has discretion; court may interfere where taxed amounts are manifestly excessive — substitution of fair flat rate permitted; procedural compliance with filing timetables mandatory (late rejoinder expunged).
22 December 2016
Court allowed partial review of taxation: separated attendance and printing disbursements, increased instruction fees to 6.5%.
Advocates' remuneration and taxation — scope of taxing officer's discretion; distinction between instruction fees and disbursements (attendance, travel, printing); proper application of percentage bands under Ninth Schedule; interpretation of 'principal sum' for taxation.
22 December 2016
A misnumbered counter-affidavit due to registry error is a curable technicality; the application is not uncontested.
* Civil procedure – misnumbered filings – counter-affidavit wrongly titled – whether misnumbering is fatal or curable under section 97 CPC and Article 107A(2)(e) – court’s duty to rectify registry errors and ensure accurate court records.
20 December 2016
Reported
Applicant granted leave to appeal over whether the leave-to-defend summary suit was filed under the correct sub‑rule.
Civil procedure – summary suits – leave to appear and defend – application under Order XXXV r.3(1)(b) v r.3(1)(c) – leave to appeal – test is whether there are prima facie grounds meriting Court of Appeal’s attention; interlocutory v final orders and appealability.
16 December 2016
Leave to appeal granted where a serious question exists whether the summary-suit defence application was brought under the correct CPC sub‑rule.
Civil procedure – summary suit – application to appear and defend – whether Leave to defend should be under Order XXXV r.3(1)(b) or r.3(1)(c) CPC; Leave to appeal – standard for grant – prima facie grounds/serious question meriting Court of Appeal's attention; Appealability – final vs interlocutory orders.
16 December 2016
Extension to file witness statements must be sought under CPC s.95 (inherent jurisdiction), not Limitation Act s.14; application struck out.
Commercial Procedure — Rule 49(2) HCCP Rules: seven‑day deadline for witness statements; Rule 2(1) — resort to CPC for lacunae; Limitation Act s.14 limited to appeals/applications; CPC s.95 (inherent jurisdiction) is proper basis for extension of time to file witness statements; applications founded on wrong provisions are struck out; "any other enabling provisions" is ineffectual.
16 December 2016
Expiry of an assigned speed track does not automatically oust jurisdiction; court may extend the schedule and not dismiss.
Civil procedure — Case management — Order VIIIA (speed tracks) — Expiry of assigned speed track does not automatically oust jurisdiction; court may extend or amend scheduling order suo motu; duty to seek departure shared by parties; procedural rules are handmaid of justice; Rules inapplicable to suits instituted before their commencement.
16 December 2016
Clerical date discrepancy on a Chamber Summons is a curable slip; court allowed amendment within a fortnight.
Civil procedure – Chamber Summons – discrepancy between date on summons and date on supporting affidavit – whether incurable defect – amendment permitted; procedural errors curable under Article 107A(2)(e).
16 December 2016
A mismatched date between a Chamber Summons and its supporting affidavit is a curable slip; amendment allowed within two weeks, no costs.
Civil procedure – Chamber Summons – Supporting affidavit date inconsistent with date on Chamber Summons – Whether defect incurable or curable by amendment – Amendment allowed where defect is a trivial, accidental slip; Article 107A(2)(e) Constitution applied; Court of Appeal authority on amendment of procedural notices relied upon.
16 December 2016
Adjudication board proceedings and foreign arbitral awards are not "suits" under CPC; res subjudice and res judicata do not apply.
* Civil Procedure — Res subjudice (s.8 CPC) — applies only to suits pending before courts as defined by the CPC; adjudication board proceedings are not "suits". * Civil Procedure — Res judicata (s.9 CPC) — operates only where an earlier matter was decided by a court competent to try the subsequent suit; foreign arbitral awards are not automatically res judicata under CPC. * Arbitration/Adjudication — Proceedings commenced by statement of claim or arbitration are not "suits" instituted by plaints and thus outside sections 8 and 9 CPC.
15 December 2016
Applicant obtained summons to show cause after court found respondent likely disobeyed clear restraining orders.
Contempt of court – alleged removal of restrained assets – proof by affidavit – clarity of restraining orders – expunged affidavit paragraphs not admissible – duty of counsel to inform clients of court orders – issuance of show-cause summons prior to committal or sentencing.
10 December 2016
Applicants' certificate of urgency dismissed; forgery allegations require forensic proof; matter to be fixed per court diary.
Urgency — Certificate of Urgency — matters requiring immediate attention; Allegations of forgery/fraud in civil proceedings — higher standard of proof; necessity of forensic/expert evidence to prove forged signatures; Judicial discretion on abridging procedure — urgency must be real and proportionate; Costs — in the cause.
1 December 2016
November 2016
Applicant's bare claim of a witness's bereavement, without particulars or documents, failed to justify extension of time.
* Civil Procedure – extension of time under section 95 CPC – applicant must show sufficient reasons and account for every day of delay. * Sufficiency of reasons – bereavement of witness – unsupported assertions insufficient; need dates and corroborating documents (death certificate, travel tickets) or witness affidavit. * Evidence – affidavits must be updated and particularized; replication of a struck-out affidavit is inadequate. * Procedural – ex parte application dismissed for want of sufficient material to justify enlargement of time.
30 November 2016
The applicant’s revision was struck out for citing the wrong statute, leaving the High Court not properly moved.
* Civil procedure – Revision jurisdiction – High Court’s power under Sections 43 and 44 of the Magistrates' Courts Act to revise civil and execution proceedings from Resident Magistrates’ Courts. * Civil procedure – Distinction between Section 79 Civil Procedure Code (High Court-initiated revisions of finalized cases) and revisions under the Magistrates' Courts Act. * Civil procedure – Requirement to cite proper enabling provisions – incorrect citation renders application incompetent. * Execution law – Execution and garnishee orders from subordinate courts fall within reviewable "proceedings of a civil nature."
23 November 2016
An arbitrator may 'cause' an award to be filed by forwarding it (with records); absence of a petition does not invalidate filing.
Arbitration — Filing of award — Section 12(2) Arbitration Act — Rule 4 GN 427/1957 — no statutory requirement that arbitrator file by petition; 'causing' award to be filed satisfied by forwarding letter and delivery (DHL/courier) — notice of filing: remedy is service/re‑service or application.
17 November 2016
Advocate’s acute illness justified setting aside dismissal for want of prosecution and restoring the case.
Commercial procedure – setting aside dismissal for want of prosecution – sufficiency of cause – advocate’s illness (medical chit) – credibility and prior conduct – interest of justice to decide matters on merits – no prejudice, restoration ordered.
16 November 2016
Court restored a suit dismissed for want of prosecution where counsel’s documented illness constituted sufficient cause.
Commercial procedure — setting aside dismissal for want of prosecution — rule 43(2) High Court (Commercial Division) Procedure Rules — counsel’s sickness and medical certificate as sufficient cause — applicant’s prior conduct and absence of prejudice — restoration to register.
16 November 2016
An application to add necessary parties under Order I r.10(2) CPC is not time-barred by the Limitation Act; objection dismissed.
Civil procedure – Order I r.10(2),(4) CPC – addition of parties "at any stage" – Limitation Act inapplicable to such applications – preliminary objection dismissed with costs.
14 November 2016
Reported
Interrogatories that seek a party’s trial evidence are impermissible; no further answers required and the case proceeds.
Civil procedure – Interrogatories – Order XI r.9 CPC – Interrogatories must seek facts or admissions, not the evidence a party will adduce at trial; impermissible fishing expeditions; court may refuse further answers and proceed to trial.
9 November 2016
Interrogatories that seek a party's trial evidence are impermissible; objections on relevance/bona fides justified refusal of further answers.
* Civil procedure – Interrogatories under Order XI r.9 CPC – Scope limited to facts material to issues; cannot extend to evidence or contents of a party's brief. * Sufficiency/embarrassing answers – Objections on irrelevance or not exhibited bona fide may justify refusal to answer further. * Court may assess propriety of previously permitted interrogatories and refuse further answers if they seek trial evidence.
9 November 2016
Applicant’s withdrawal to avoid objection does not prevent costs; costs follow the event.
Companies — winding-up petition — withdrawal to preempt preliminary objection — costs follow the event; Civil Procedure — general rule that costs follow the event; absence of reply not a bar to entitlement to costs.
7 November 2016
Plaintiff's breach of mandatory pleading format led to striking out; legal‑personality dispute requires evidential determination.
Commercial Procedure Rules — mandatory pleading format (Rule 19(1)) — non‑compliance attracts rejection/striking out; Preliminary objection — issues requiring evidence (legal personality) not decidable on PO (Mukisa principle); Amendment under Order VI r.17 cannot pre‑empt a pending preliminary objection; Distinction between rejection at filing and striking out after filing.
4 November 2016
Suit for redemption dismissed as time‑barred; Power of Attorney registration not compulsory and locus standi issue rejected.
Limitation law – Redemption of land – Cause of action arises on repayment; 12‑year limitation (Law of Limitation Act, para 17 Part I) applies. Land Act s.120(1) – "any time" refers to discharge timing before sale, not commencement of cause of action. Registration of Documents Act – Power of Attorney not compulsorily registrable under s.8; registration optional under s.11; locus standi not defeated at preliminary stage absent evidence.
4 November 2016
Court granted extension to file witness statements, finding sufficient cause from inability to obtain public officers' names; summons refused.
* Civil procedure – extension of time – discretionary relief under Law of Limitation s.14(1), rule 49 High Court (Commercial Division) Procedure Rules and CPC s.95 – requirement to show sufficient cause. * Evidence – public officers’ transfers/reshuffles as a legitimate cause for delay in obtaining witness identities and statements. * Procedure – summons to a public official should not issue before witness statements/names are filed.
4 November 2016
Court stayed proceedings for arbitration after finding applicant willing to arbitrate and respondent failed to prove obstruction.
* Arbitration law – stay of court proceedings under section 6 of the Arbitration Act – existence of arbitration clause – requirement of willingness to arbitrate – burden to prove obstruction of arbitration. * Civil procedure – effect of correspondence (letters and emails) on arbitration timetables and readiness to arbitrate.
3 November 2016
Whether to stay court proceedings to enforce an arbitration clause under section 6 when parties dispute willingness to arbitrate.
* Arbitration Act s.6 – stay of court proceedings – enforcement of arbitration clause – requirements: willingness to arbitrate, absence of steps in court, convenience and justification for refusal. * Arbitration clause (contractual) – disputes to be referred to arbitration before court action. * Evidence – burden to prove obstruction of arbitration; email communication as notice and proof of receipt.
3 November 2016
Judge refused recusal where allegations arose from judicial decisions, not extrajudicial or personal bias.
Recusal — procedure for seeking judicial disqualification — affidavit by party versus counsel-led chamber application; Judicial bias — extrajudicial/personal bias required for disqualification; Objective test — reasonable apprehension of bias of a fair-minded informed observer; Judicial discretion — striking out preliminary objections and setting timetables not proof of bias; Professional conduct — advocates’ duty to use proper recusal procedure and not use affidavits to delay proceedings.
2 November 2016
Concession by respondent does not justify deferring costs; successful applicant entitled to immediate costs.
Civil procedure – costs – general rule that costs follow the event – application conceded by respondent – whether concession justifies ordering costs in the cause – applicability of costs rule to interlocutory applications.
2 November 2016
Respondent’s concession does not bar immediate costs; applicant awarded costs and ordered to file defence within fortnight.
Civil procedure – costs – general rule that costs follow the event; section 30(2) CPC – requirement to state reasons when departing from the rule; interlocutory applications – principle applies; concession by respondent does not automatically justify reserving costs to the main suit; award of costs to successful applicant; timetable for filing defence.
2 November 2016
Late amendment to pleadings to introduce forensic report refused for introducing new cause of action, prejudice and bad faith.
Civil procedure – amendment of pleadings; Commercial Division Rules r.24 – leave to amend after scheduling order; amendment introducing new cause of action (forgery) inconsistent with pleaded internet‑banking loss; prejudice and joinder of third party; bad faith and delay.
1 November 2016
October 2016
Whether a faxed copy is admissible as secondary evidence when the original’s unavailability is not proved.
Evidence — Secondary evidence — Admissibility of faxed copy — Conditions under section 67(1)(a)(i) & (iii) Evidence Act — Notice to Produce — Insufficiency of counsel’s oral statement — Consistency with prior ruling.
28 October 2016
Court granted extension to file defence after earlier defence was struck out, holding sufficient reasons shown.
* Commercial procedure – extension of time to file written statement of defence – applicability of rule 20(2) where defence was filed in time but later struck out. * Civil Procedure Code cited alongside Rules – wrong citation not fatal where relevant Rule is relied upon. * Sufficient reasons – bona fides and prompt action after strike-out justify extension. * Evidential objections – affidavit of counsel acceptable where overall explanation is satisfactory.
27 October 2016
Reported
Appeal to Commercial Division proper where subordinate civil suit involves contractual breach of confidentiality; preliminary objection overruled.
Commercial Division jurisdiction — Rule 69(1) — classification of 'commercial case' determined by substance of cause of action — breach of confidentiality arising from lending contract is commercial — absence of special register in subordinate court irrelevant — belated procedural objections may be struck out.
26 October 2016
Whether the Commercial Division may hear an appeal where the dispute arises from contractual confidentiality in lending.
Commercial Division jurisdiction – Meaning of "commercial case" – Whether subordinate court registration or title determines commercial nature; Contractual confidentiality in lending business qualifies as commercial; Preliminary objections must be timely and with reasonable notice; Late procedural points may be struck out.
26 October 2016
Conflict allegations against counsel require evidence; affidavits must disclose sources and must not contain prayers.
* Civil procedure – Preliminary objection – pure point of law principle (Mukisa Biscuit) – factual disputes requiring evidence not for determination at PO stage. * Conflict of interest – allegation that advocate is company secretary – burden on alleging party to prove conflict; not decidable on PO without evidence. * Affidavits – source of information and use of "I was informed" acceptable if source disclosed; affidavits must not contain prayers – offending paragraphs to be expunged. * Locus/hearsay – objections must be adequately argued to succeed.
24 October 2016
Dismissal of defendant's extension application entitled plaintiff to summary judgment; court awarded claimed monetary relief and costs.
* Civil procedure — Summary judgment — Order XXXV r.2(2)(a) CPC — effect of dismissal of application for extension to seek leave to appear and defend. * Commercial Division procedure — rule 67(3) H.C. (Commercial Division) Procedure Rules, 2012 — proceeding to decree after summary judgment. * Remedies — monetary awards in summary proceedings (overdue rental, business inconvenience, general damages, costs).
20 October 2016
Dismissal of defendant's extension application entitled plaintiff to summary judgment and monetary awards under Order XXXV r.2(2)(a).
* Civil procedure – Summary judgment – Order XXXV r.2(2)(a) CPC – entitlement to summary judgment where application for extension to seek leave to appear and defend dismissed. * Commercial division procedure – High Court (Commercial Division) Procedure Rules r.67(3) – entry of decree following summary judgment. * Remedies – contractual debt and damages for business inconvenience and general damages.
20 October 2016
Summary judgment granted after defendants failed to prosecute; plaintiff awarded debt, interest and costs.
* Commercial law – Summary judgment – Order XXXV rule 2(2)(a) & (b) CPC – entitlement to summary judgment where defendant fails to prosecute extension application. * Procedure – Dismissal for want of prosecution – effect on defendant's right to appear and defend. * Relief – Debt recovery – decretal sum, pre-judgment interest at base rate (20%), post-judgment interest (7%), and costs. * Alternative remedies – receiver/possession not granted in absence of necessity.
19 October 2016
Affidavit statements based on others must disclose sources; offending paragraphs expunged and application allowed to proceed.
Contempt proceedings; Order XXXVII r.2(2) - detention for breach of injunction; Affidavit requirements - Order XIX r.3 - disclosure of sources for information; Defective affidavit paragraphs to be expunged, not necessarily whole affidavit; Amendment impermissible where it preempts a preliminary objection.
17 October 2016
Execution denied where the company named in the execution was not the party to the arbitration/decree.
Execution – identity of judgment debtor – requirement that party names correspond to those in original proceedings; arbitral award registration and challenges in execution proceedings; committal of company officers – corporate personality and lifting the veil; Order XXI procedure and affidavit requirement.
17 October 2016
A branch lacks juristic personality and was struck out; costs awarded to defendants; suit proceeds against the main defendant.
* Commercial Division – preliminary objection – impleading a branch of a company which lacks separate legal personality. * Corporate law – legal personality – branches have no independent juristic status and cannot sue or be sued. * Civil procedure – remedy for improper impleading – striking out the improperly impleaded party only. * Costs – costs follow the event under section 30 CPC; successful party on preliminary objection entitled to costs.
3 October 2016
A bank branch lacks separate legal personality; the branch was struck out and costs awarded to the successful objector.
Banking law – legal personality – Branches of banks lack independent legal personality and cannot sue or be sued; civil procedure – improper impleading – striking out branch only; costs – general rule that costs follow the event; party entitled to costs on successful preliminary objection.
3 October 2016
Court allowed interrelated omnibus application and extended commercial case lifespan, holding procedural time limits are flexible to prevent injustice.
Commercial procedure — Extension of time and enlargement of lifespan under High Court (Commercial Division) Rules — Permissibility of omnibus applications where prayers are interrelated — Procedural time limits as handmaid, not mistress, of justice — Expiry of lifespan does not automatically render suit incompetent.
1 October 2016
September 2016
Oversight by the applicant's advocate is not sufficient cause to extend time to file a notice of appeal.
* Civil procedure — Extension of time to appeal — Requirement of sufficient cause before enlargement of time. * Appellate practice — Oversight, laxity or ignorance of the law by counsel does not amount to sufficient cause. * Rules of court — Must prima facie be obeyed; court needs material to exercise discretion to extend time. * Relevant authorities: Ratman v Cumarasamy; Calico Textile Industries Ltd; Fortunatus Masha cited.
30 September 2016
Execution application improperly brought and dismissed where the decree had been adjusted and satisfied by payment.
Execution of decree — procedural compliance with Order XXI Rule 10(2) (tabular form and specifying mode of execution); improper citation of enabling provisions; omnibus applications (combining show-cause and arrest) are defective; execution barred where decree was adjusted and satisfied by consent/payment; remedy aggrieved party is appeal.
21 September 2016
A temporary injunction under Order XXXV/XXXVII cannot be sought against persons who are not parties to the suit.
Civil procedure — Temporary injunction — Order XXXV/XXXVII Rule 2(1) Civil Procedure Code — injunctions directed at the defendant only — injunction cannot be issued against strangers to the suit — preliminary objection upheld; non-parties struck out.
15 September 2016
August 2016
A disputed statutory interpretation is not a manifest error for review; appeal, not review, is the proper remedy.
Companies law; Insurance regulator v. financial creditor — whether statutory demand under s.280( a) applies to Commissioner of Insurance; distinction between s.280 and s.281 procedures; manifest-error review standard; appeal vs review; insufficiency of skeleton arguments for deciding merits.
3 August 2016
Reported
Review denied: whether the insurance regulator is a 'financial creditor' under Companies Act is a debatable legal issue, not a manifest error.
Companies law / insolvency – whether statutory regulator (Commissioner of Insurance) is a ‘financial creditor’ obliged to issue 21‑day statutory demand under s.280(a) – scope of review: manifest error apparent on face of record vs. debatable point of law; procedural sufficiency of skeleton arguments vs. full written submissions.
3 August 2016
July 2016
Ex parte decree set aside where defective service, publication misstatement and inconsistent process affidavits constituted "special circumstances".
Civil procedure — service of process — substituted service by publication — misstatement of address in publication — inconsistent process-server affidavits — "special circumstances" under Order XXXV r.4/Order IX r.13(1) to set aside ex parte decree.
25 July 2016