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.

305 judgments
  • Filters
  • Judges
  • Alphabet
Sort by:
305 judgments
Citation
Judgment date
December 2021
High Court suspended execution after finding a pending Court of Appeal stay application despite disputed service.
* Commercial procedure — execution of decree — suspension of execution pending appellate stay. * Stay of execution — pendency of Court of Appeal application — proof by affidavit and court-endorsed filing. * Service — alleged non-compliance with Rule 55(1) Court of Appeal Rules — relevance and forum for determination. * Discretion to suspend High Court execution where appellate proceedings are pending.
22 December 2021
Pendency of appeal does not stay execution; judgment debtor may be detained for unpaid taxed costs absent a stay.
Execution — enforcement by arrest and detention for unpaid taxed costs; pendency of appeal does not automatically stay execution; stay must be obtained from relevant authority; Order XXXIX Rule 5(2) cited; civil imprisonment conditions and upkeep deposit.
21 December 2021
Judgment debtor’s claims against third parties do not prevent committal for non‑payment absent a stay of execution.
Civil procedure – committal for civil debt – requirement to show sufficient cause to avoid committal – absence of stay of execution – third‑party indebtedness not a ground to defer execution.
21 December 2021
The respondent breached loan and settlement agreements; the applicant awarded TZS 369,148,919.10, damages, interest and costs.
* Contract law – loan facility – breach of loan agreement and breach of Deed of Settlement for failure to pay agreed instalments. * Civil procedure – maintainability – non-joinder/misjoinder objection; Order I r.9 CPC; judgment on admission (Order XII r.4). * Remedies – declaration of indebtedness, award of damages, interest and costs.
15 December 2021
Court registered and entered the arbitral award as judgment after dismissing the respondent’s challenge, awarding specified sums, interest and costs.
Arbitration Act, s73 — registration and enforcement of arbitral award as court judgment; Arbitration Act, s75 — challenge to arbitral award and dismissal; Leave to enter judgment; Enforcement of awards — VAT, penalties, interest, costs, arbitrator's fees, coordination expenses; Quantification and reduction of general damages.
15 December 2021
A party who fails to object during arbitration cannot later challenge the arbitrator's appointment or award.
Arbitration — challenge to award for manifest serious irregularity; appointment of arbitrator — role of appointing authority vs. regulatory list (NCC); necessity to raise jurisdictional/appointment objections during arbitral proceedings (Arbitration Act ss35–36); correct statutory basis for setting aside awards (Arbitration Act s75).
15 December 2021
Preliminary objection on time-bar dismissed; omnibus late application to set aside ex parte orders allowed to proceed where prayers are interrelated.
* Limitation — Section 14(1) Law of Limitation Act — court's discretion to extend time; * Civil Procedure — Rule 32(2) High Court (Commercial Division) Rules — applications to set aside ex parte orders; * Civil Procedure — omnibus applications — when combining prayers is competent (interrelatedness test); * Procedure — preliminary objection on limitation — merits and disposition.
13 December 2021
Where specific Companies Act provisions govern winding up, reliance on general CPC provisions is improper and renders the application incompetent.
* Companies Act – winding up – interim orders – specific statutory provisions govern interim relief in winding up proceedings (s.281/282/284) and must be cited.* Civil Procedure Code – general procedure cannot supplant specific statutory procedure where such exists.* Civil procedure – preliminary objection – wrong citation of enabling provision renders application incompetent.* Procedural compliance – late filed submissions to be disregarded.
12 December 2021
An inadvertent misnomer in a plaintiff's name is curable and does not invalidate a plaint or its cause of action.
Civil procedure – preliminary objection – whether plaint discloses cause of action (Order VII r.1); misnomer in party's name – curable error; defendant changing the substance of filed objection without leave; overriding objective and interest of justice; costs where defect inadvertent.
10 December 2021
10 December 2021
Applicant proved ownership/possession and obtained lifting of attachment under Order XXI Rules.
Civil procedure – Attachment – Objection to attachment – Requirement under Order XXI Rule 58 to show interest or possession at date of attachment – Evidence of licence, possession and joint venture agreement – Warrant of attachment lifted under Order XXI Rules 57(1) and 59.
10 December 2021
Applicant failed to show arguable legal issues; leave to appeal under section 5(1)(c) was denied.
* Appellate Jurisdiction Act s.5(1)(c) – leave to appeal – covers every High Court decree, order, judgment, decision or finding. * Costs and taxation – challenge to instruction fees assessed under Advocates Remuneration Order – whether dismissal for want of prosecution precludes fees. * VAT on taxed costs – interpretation of order and whether VAT issue raises arguable point of law.
10 December 2021
Court refused transfer and striking out; commercial petition in main registry was properly instituted and may proceed.
* Company law – Commercial petitions – Appropriate registry for institution – application for transfer under High Court Registries Rules 2005 (Rule 7(1) and 7(4)). * Civil procedure – res judicata / res sub judice and abuse of process – striking out petitions – when duplication justifies striking out. * Civil Procedure Code – Order XLIII Rule 2 – oral applications and procedural safeguards. * Certificate of urgency – justification for filing in main registry and timely disposal of commercial disputes.
10 December 2021
Defendant breached hire-purchase by defaulting on payments; court awarded outstanding price, interest, damages and costs.
Contract law – Hire-purchase agreement – Delivery and proof of delivery – delivery note not conclusive; corroboration by registration and payment schedule – Acknowledgement of debt – Breach by non-payment – Contractual interest and post-judgment interest – General damages and costs.
10 December 2021
Court allowed additional forensic evidence subject to certification and fees, holding witness competent and dispensing with notice to produce.
Evidence — additional evidence under Court of Appeal Rule 36; competence to tender exhibits — possession/knowledge suffices; secondary evidence — Section 68(g) discretionary waiver of notice to produce; public documents — certification and fees required under Sections 83 and 85 of the Evidence Act.
8 December 2021
Denial of the applicant's right to be heard and failure to follow agreed arbitration procedure nullifies the arbitral award.
* Arbitration law – failure to follow agreed arbitration procedure (NCC Arbitration Rules) – Rule 10(1) – duty to fix hearing dates and give notice. * Natural justice – right to be heard – section 35(1)(a) Arbitration Act, 2020 – breach renders award a nullity. * Serious irregularity under section 70 – setting aside arbitral awards. * Procedural fairness outweighs expedience; proof of prejudice not required where right to be heard violated.
8 December 2021
8 December 2021
Court set aside consent decree obtained by fraud, restrained sale of matrimonial property and ordered disciplinary inquiry into counsel.
Civil procedure — execution and attachment — Order XXI Rules 57–58 — investigation of claims to attached property; Contract capacity and fraud — forged signatures and minor's incapacity vitiating security documents; Consent judgments — fraud as ground to set aside compromise and decree; Advocate conduct — conflict of interest and possible disciplinary referral.
8 December 2021
Objection to execution dismissed as sale was already concluded and application overtaken by events.
Execution – Objection to attachment – Order XXI Rules 57–59 CPC – Requirement of pending attachment; Overtaken-by-events doctrine – Completed execution and certificate of sale; Section 95 CPC not to be used where specific procedure applies; Court will not undo already executed decree.
7 December 2021
Attachment warrants lifted where a non-party proved interest/ownership in attached vehicles and machinery by documentary evidence.
Civil Procedure Code Order XXI Rule 58 – Attachment and execution – Proof of interest in attached property by a non-party – Evidence: vehicle registration cards, sale agreements, bank transfer forms, warranty documents; lifting attachment where interest established.
7 December 2021
Applicant proved proprietary interest in attached vehicles and plant; court lifted attachment and awarded costs.
Execution law – Attachment – Order XXI Rule 58 – Proof of proprietary interest by registration cards, sale agreements, bank transfers and warranty documents – Non-party to main suit – Lifting of warrants of attachment.
7 December 2021
Applicant failed to prove respondent lacked Tanzanian immovable property; security for costs application dismissed.
Security for costs — Order XXV r.1(1) CPC — foreign plaintiff — requirement of no sufficient immovable property in Tanzania — burden of proof rests on the party alleging non‑existence of property (Section 110 Evidence Act) — need for tangible corroborative evidence.
7 December 2021
Court refused to order FIU investigation after applicant had already reported alleged fraud, finding the application overtaken by events.
Civil procedure – Application under section 95 CPC to compel third-party investigative action – Misuse where complainant has already reported to police/FIU; Anti-Money Laundering Act – FIU exercise of discretion to investigate; procedural appropriateness of court ordering FIU to investigate alleged fraud.
7 December 2021
Court registers parties' deed of settlement under Order XXIII Rule 3 and enters consent judgment, marking suit settled.
* Civil procedure – Consent judgment – Registration and recording of a deed of settlement under Order XXIII Rule 3 of the Civil Procedure Code – Effect of deed as part of the court's decree.
6 December 2021
Taxing Officer’s wholesale disallowance of costs set aside; fresh taxation directed due to breach of taxation principles.
Advocates’ costs – taxation – application of Orders 12 and 48 of the Advocates Remuneration Order, 2015 – when to tax off entire bill – finality and remittal to another Taxing Officer.
6 December 2021
Court set aside total disallowance of a bill of costs and ordered fresh taxation by another Taxing Officer.
* Advocates Remuneration Order 2015 – taxation of costs – Order 12 (principles of taxation) vs Order 48 (disallowance where >1/6 disallowed). * Excessive instruction fees – appropriate reduction where claimed amount far exceeds scale and lacks certificate for multiple advocates. * Taxation procedure – taxing officer’s quantum determinations generally final; fresh taxation before another Taxing Officer warranted where principles misapplied.
6 December 2021
Adjournment denied and suit dismissed where claimed witness illness lacked medical proof.
Adjournment – illness of witness – necessity of medical proof for adjournment – Commercial Division Procedure Rules, Rule 46(2)(b) and Rule 56(2) – striking out witness statements – dismissal under Order IX Rule 5 Civil Procedure Code.
6 December 2021
Default judgment entered for bank loan recovery; execution stayed pending required newspaper publication.
Commercial law – Default judgment under Rule 22 – substituted service by newspaper publication – sufficiency of Form No.1, supporting affidavit and annexures – interest awarded and publication requirement before execution (Rule 22(2)).
3 December 2021
Leave to appeal granted due to unresolved jurisdictional and retrospective-effect issues under the 2018 copyright amendment.
* Appellate procedure — leave to appeal — discretionary but granted where serious, arguable legal issues exist; * Copyright law — jurisdiction to adjudicate infringement in light of amendments to the Copyright and Neighbouring Rights Act; * Retrospectivity — whether the 2018 amendment applies to cases instituted before amendment.
3 December 2021
Leave to appeal granted on unsettled jurisdictional and retrospective-effect issues under the Copyright Act amendments.
* Civil procedure – Leave to appeal – discretionary, not automatic – granted where serious or unsettled points of law arise. * Intellectual property – Copyright and Neighbouring Act – jurisdiction to determine infringement; effect and retrospective application of 2018 amendment.
3 December 2021
Foreign ICC award held unenforceable in High Court while conflicting domestic default decree remains in force.
Arbitration — International (seat outside Mainland Tanzania) — applicability of domestic set-aside provisions — interplay between court judgments and foreign arbitral awards — conflict of decrees and public policy — proof threshold for fraud/corruption allegations against arbitral process.
2 December 2021
Unsigned replacement contracts held binding by conduct; defendant liable for unpaid invoices, interest and damages.
Contract by conduct – unsigned replacement agreements – acceptance by performance and conduct; Enforcement of invoice terms – late-payment charges as interest; Breach of contract – unpaid invoices; Damages and interest (pre‑ and post‑judgment) awarded; Admissibility and weight of documentary evidence and correspondence confirming liability.
2 December 2021
Court apportioned blame for an unreturned container but held the defendant liable for non-delivery of a dump truck (USD 55,607).
• Contract law – carriage and C&F agreements – liability for loss or delayed return of containers; contractual limitation and indemnity clauses. • Remedies – entitlement to demurrage/compensation for non-delivery of cargo; interest on judgment debt. • Frustration – doctrine not available where performance is merely more onerous or commercially difficult. • Mitigation/duty to mitigate – refusing to pay retained invoices and seizure of opponent's documents may reduce claimant's recovery; apportionment of blame. • Civil procedure – counterclaim absence does not bar court from considering defensive evidential matters for fairness.
1 December 2021
Whether a correspondent bank breached an interim restraining order by debiting funds under a letter of credit.
Commercial injunctions; interim restraint on encashment of letter of credit; NOSTRO account debit after interim order; alleged contempt of court; obligation of correspondent bank to respect court orders.
1 December 2021
November 2021
The applicant’s affidavit verification was adequate; preliminary objection alleging hearsay and defective verification dismissed.
* Civil procedure – Affidavit verification – Whether verification clause must state sources for facts based on information – Order XIX Rule 3(1)&(2) CPC and Rule 74 High Court (Commercial Division) Rules. * Affidavits by corporate entities – competence of principal officer to depose to court records and litigation matters. * Hearsay – court records and beliefs grounded on stated facts may be properly averred by responsible officer.
30 November 2021
Application to restore mediation struck out as premature because no dismissal order existed; matter was remitted to the trial judge.
* Commercial Court — Mediation — Alleged dismissal of mediation — Whether a dismissal order existed — Remittal of file to trial judge for orders under Rule 36 — Prematurity and incompetence of restoration application.
30 November 2021
An MOU and course of dealings established a binding debt; undue influence and COVID‑19 defences failed.
Contract formation – inferred from conduct and course of dealings; Memorandum of Understanding (MOU) – may be binding depending on terms; Undue influence – burden to plead and prove, not established where signing occurred post-release and in presence of counsel; COVID‑19 – not automatic force majeure absent evidence or agreement; Remedies – decretal sum, interest and general damages.
30 November 2021
A witness may identify and rely on documents already admitted as exhibits; identification is not a re-tendering or surprise.
Evidence — Witness identification of exhibits — distinction between identification and tendering — admissibility of documents — Rule 49(1) High Court (Commercial Division) Procedure Rules — Rule 4 overriding objective/substantive justice — rule against surprise.
29 November 2021
Court enforces renewed credit facility and continuing securities, holding guarantors jointly and severally liable for unpaid loan.
* Commercial law – credit facility – renewal of overdraft and term loan under facility letter dated 18 July 2016 * Securities – continuing general debenture, corporate guarantee and personal guarantees as continuing security * Contract of guarantee – guarantors jointly and severally liable; liability coextensive with principal debt * Remedies – judgment for outstanding sum, contractual (penalty) interest, court interest, costs and realization of charged assets
26 November 2021
High Court lacked jurisdiction to hear challenge to TRA charges; Tax Revenue Appeals Board has exclusive original jurisdiction.
* Tax law – Jurisdiction – Section 7 Tax Revenue Appeals Tribunal Act vests sole original jurisdiction in the Tax Revenue Appeals Board for civil disputes under revenue laws. * Companies law – Administration – Section 249(1)(c) protects a company only during the petition-to-order period; it does not indefinitely bar actions after an administration order. * Conflict of jurisdictions – High Court lacks jurisdiction to challenge Commissioner General's exercise of powers under revenue laws where Tribunal jurisdiction applies.
26 November 2021
Court registered the parties' deed of settlement as a consent judgment and marked the suit settled on compromise.
Civil Procedure — Consent judgment — Registration and adoption of Deed of Settlement under Order XXIII Rule 3 — Suit marked settled on compromise — Incorporation of settlement terms into judgment and decree.
26 November 2021
An unconditional demand guarantee is not absolute; material variation or beneficiary’s breaches of underlying terms can discharge the guarantor.
* Banking & guarantees – demand payment under an “irrevocable/unconditional” payment guarantee – interplay between bond terms, URDG 2010 and underlying credit facility. * Contract law – suretyship – material variation/discharge of guarantor (Section 85 Law of Contract Act). * Equity – clean hands doctrine prevents beneficiary profiting from its breaches. * Security arrangements – failure to open escrow, unauthorized release of collateral, absence of monitoring reports as defenses to guarantee claims.
26 November 2021
Default judgment granted for refunds and return of gold; specific damages rejected for lack of pleading and proof.
* Commercial procedure – Default judgment – Rule 22(1) High Court (Commercial Division) Procedure Rules – entitlement where defendants fail to file written statements of defence and substituted service is proved. * Evidence – Proof of claim in default proceedings – refund of money and return (or value) of goods vs. specific (special) damages which must be pleaded and strictly proved. * Remedies – general damages assessment, interest (pre- and post-judgment) and costs. * Execution procedure – publication requirement under Rule 22(2) before execution of a default decree.
26 November 2021
Whether alleged misrepresentation vitiated the home-loan contract and whether substitution of mortgage security was agreed and breached.
Contract law – Misrepresentation – Burden of proof; Guarantee and substitution of security – enforceability of oral/written substitution agreement witnessed by bank officer; Liability of principal debtors for default – indemnity to guarantor; Remedies – monetary indemnity, discharge and substitution of mortgage, injunction, costs.
26 November 2021
A counterclaim is a separate pleading for page‑limit purposes; the applicant's page‑limit objection was overruled.
Commercial procedure – Rule 19(1) (page‑limit for pleadings) – Whether counterclaim counts toward the ten‑page limit; Civil Procedure Code – Order VIII (counterclaim and subsequent pleadings) – counterclaim as separate pleading; Overriding‑objective principle – relaxation of procedural defects to secure substantive justice; Preliminary objection – appropriate timing and effect.
25 November 2021
Ambiguous pleadings raised limitation issue; court allowed plaintiff to amend plaint to clarify contract or tort basis.
Limitation of actions; distinction between breach of contract and tort (fraud); fraud as independent cause of action; discovery rule for fraud; overriding objective and leave to amend pleadings.
24 November 2021
Photocopy of a lost lease is admissible where defendant fails to deny and witness had knowledge and access.
Evidence Act s66, s67(1)(b),(c) – secondary evidence – admissibility of photocopies of lost originals; Order VIII Rule 5 CPC – omission in pleadings treated as admission; competence to tender – witness with knowledge and prior access; no absolute requirement for police loss report.
24 November 2021
Suit for discharge and release of a title deed struck out because an earlier judgment already granted identical relief.
* Civil procedure – effect of prior judgment – where earlier judgment ordered discharge of mortgages and release of title deeds, subsequent suit seeking same relief struck out. * Res judicata/res‑subjudice – Court will not issue duplicate orders affecting same property already dealt with by earlier effective order. * Mortgage law – discharge and release of title deeds following satisfaction of banking facilities as ordered by court.
23 November 2021
Respondents' undertaking not to enforce securities preserved the status quo pending determination of jurisdictional objections.
* Commercial law – interim relief – application for injunction to restrain enforcement of securities pending main suit. * Status quo – undertaking by respondent in lieu of interim injunction accepted and certified. * Jurisdiction – choice‑of‑court clause may dispose of the main suit and thereby affect interlocutory applications.
23 November 2021
Published terms of business formed a unilateral contract making the respondent liable for negligent cargo handling and loss.
* Contract law – unilateral contract – Terms of Business held to create binding obligations to consignees. * Negligence – terminal operator liable for damage caused by its handling machinery. * Evidence – burden and standard of proof in civil claims; acceptance on balance of probabilities. * Insurance – withdrawal of insurer claim does not preclude direct contractual recovery. * Remedies – award of principal, general damages, court interest and costs.
23 November 2021