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.

33 judgments
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33 judgments
Citation
Judgment date
October 2021
Applicant failed to prove interest or possession to prevent sale; registered mortgage of the respondent prevailed.
Civil Procedure – Order XXI Rules 57–61 – objection to attachment – burden on claimant to prove interest or possession at attachment; Property law – registered legal mortgage prevails over unregistered contractual claims; Registration of documents affecting land – relevance to priority and enforceability of interests in land.
29 October 2021
Plaint fails to disclose a cause of action against director; corporate veil not lifted, director struck out with costs.
Civil procedure — Preliminary objection — Whether plaint discloses cause of action; corporate personality — separate legal entity; lifting corporate veil — requirements for personal liability of director; striking out defendant for failure to plead cause of action.
29 October 2021
Applicant granted extension where technical defects caused strike-out, prompt action and apparent point of law warranted condonation.
Civil procedure – Extension of time – Good cause – Technical delay due to incomplete record – Diligence and accounting for days of delay. Electronic filing – date of electronic submission is the effective filing date. Point of law/illegality – time-bar apparent on record can justify extension of time.
27 October 2021
Applicant failed to prove intent to defraud or irreparable loss; temporary injunction dismissed.
Civil procedure – temporary injunctions – Order XXXVII r.1(b) and section 68(e) CPC – requirement to show intention to dispose of property with a view to defraud creditors and likelihood of irreparable loss (nugatory judgment). Interim relief – balance of convenience and adequacy of damages as alternative remedy. Evidence – necessity of tangible proof of imminent sale or fraudulent intent to justify restraining asset disposition.
26 October 2021
Court declared attachment and eviction threats void, granted permanent injunction and awarded costs to the applicants.
Execution/Attachment — legality of attachment of property in execution; Declaratory relief and permanent injunction against eviction; Costs — discretion under s.30 Civil Procedure Code; costs follow the event; urgent chamber summons.
22 October 2021
Third parties must formally claim property interests under Order XXI after attachment; a judgment debtor cannot defeat execution at show‑cause stage.
Civil procedure – execution of decree – show‑cause proceedings – allegations of third‑party interests and encumbrance; Order XXI Rules 53(1) and 57(1) – third parties must object post‑attachment; judgment debtor cannot substitute for third‑party claim.
22 October 2021
Alleged civil contempt for breaching a prohibitory order must be proved beyond reasonable doubt.
Civil contempt – breach of prohibitory order – standard of proof – breach must be proved beyond reasonable doubt; Service of order – requirement for notice to judgment debtor; Evidence – affidavits, need for cogent evidence and cross-examination; Remedies – committal applications for civil contempt carry penal consequences and require criminal standard proof.
20 October 2021
Committal for civil contempt requires proof beyond reasonable doubt; alleged breach here was not so proven.
Civil contempt – breach of prohibitory order – carries penal consequences – standard of proof is beyond reasonable doubt. Service of order – requirement that judgment debtor be served with prohibitory notice under Order XXI r.53(1). Evidence – submissions are not evidence; need for cogent, direct evidence (witnessing or incontrovertible proof) to establish contempt.
20 October 2021
Validity of loan facilities, mortgage and guarantees upheld; defendants liable for TZS 1,536,804,520.86 plus interest and costs.
Commercial law – validity of loan and facility agreements – signatures and common seal; burden of proof on alleged forgery. Secured lending – mortgage of land and personal guarantees – requirements and evidentiary proof. Land law – service and sufficiency of default notice under section 127 of the Land Act. Civil procedure – assessment of quantum from loan statements and interest awards; costs follow the event.
18 October 2021
Plaintiff proved supply and breach; awarded outstanding balance, general damages, and interest; special damages not proved.
Contract — Sale of goods — Existence of contract established by LPOs, delivery notes and invoices; breach by non-payment. Damages — Special damages must be strictly proved; commercial pre-judgment interest and bank charges denied for lack of proof. Remedies — Decretal sum awarded, general damages, pre- and post-judgment interest and costs.
18 October 2021
Ex-parte finding: borrower breached overdraft and guarantors jointly liable to repay outstanding loan with interest.
Commercial law – overdraft facilities – breach of credit agreement – enforcement of mortgages, debentures and personal/director/shareholder guarantees – liability of guarantors – recovery from present and future assets – contractual and penal interest – ex-parte judgment.
18 October 2021
Plaintiff proved breach but only partial debt through pleaded dishonoured cheques; awarded specific sums, general damages, interest and costs.
Contract law – breach of contract for unpaid goods supplied on credit – proof of special damages requires orders, delivery/consignment notes and tax invoices; ledger alone insufficient – admissibility of unpleaded exhibits – dishonoured cheques as evidence – interest: commercial interest requires contractual or due-date proof; court may award interest on decretal sum – award of general damages and costs.
18 October 2021
A valid cession/assignment of debt confers on the assignee the right to sue despite the doctrine of privity.
Contract law – Doctrine of privity – cession/assignment of contractual rights as an exception to privity; assignee/cessionary may sue in place of assignor. Civil procedure – Plaint must be read with annexures to determine cause of action; preliminary strike-out under Order VII Rule 11. Assignment/cession – rights may generally be ceded without debtor’s consent; obligations require consent.
15 October 2021
Leave to appeal granted where the applicant raised sufficient legal issues challenging compliance of a default judgment with Order XX rules.
Appellate jurisdiction – Leave to appeal under s.5(1)(c) AJA – grantable where point(s) of law or public importance arise; Civil procedure – Default judgment – compliance with Order XX rules 4 & 5 CPC; Leave to appeal – requirement of reasonable prospects or disturbing features warranting Court of Appeal guidance; Costs awarded to successful leave applicant.
15 October 2021
Applicant claiming monetary refund failed to show entitlement to an injunction restraining respondents' assets; application dismissed.
Commercial law – interim relief – temporary injunction – Attilio v. Mbowe test: prima facie case, irreparable loss, balance of convenience. Monetary claims – claim for refund of money does not automatically permit injunction restraining disposal of respondents' property. Civil procedure – requirement to identify subject matter/property when seeking injunctive relief (Order XXXVII); appropriate remedy for securing monetary claims is pre-judgment attachment under Order XXXVI Rule 1(a)(iii).
15 October 2021
Oral shipping agreement, later written payment plan, breached; plaintiff proved unpaid USD 849,730 and recovered judgment with costs.
Commercial law – contract for carriage and agency services – oral agreement reduced to written debt repayment agreement – invoices payable within 30 days – proof of contract by conduct and statement of account – breach and recovery of unpaid invoices; ex parte proceedings where defendant failed to file witness statements.
15 October 2021
Plaintiff's claim on a performance bond dismissed as time‑barred; prior ruling did not decide limitation.
Limitation of actions – performance bond/guarantee – cause of action accrual on call and refusal – Law of Limitation Act s.3; Surety liability – co‑existence with principal debtor – Law of Contract Act s.80; Effect of arbitration – does not necessarily suspend limitation against guarantor; Res judicata – prior dismissal must have decided limitation to bar subsequent suit.
15 October 2021
The court granted execution and prohibitory orders after judgment debtors defaulted and failed to obtain a stay of execution.
Execution of decree — Default under deed of settlement — No stay of execution obtained — Adjournment to sell property insufficient — Prohibitory orders under Order XXI Rule 53(1) Civil Procedure Code — Grant of execution.
13 October 2021
Failure to file court-ordered witness statements after final pre-trial directions warrants dismissal for want of prosecution.
Commercial Procedure  Rule 48 (as amended)  final pre-trial conference determines manner of evidence; failure to file ordered witness statements equates to failure to prosecute and warrants dismissal; Rule 2(2) permits application of CPC (Order IX r.5) to fill lacuna.
13 October 2021
Court wound up two companies for mismanagement and disputes, appointed a liquidator, and recognised a secured creditor.
Companies law – Winding up – Just and equitable and inability to pay debts (s.279(1)(d) & (e)) Standing – Contributory/director with shares held over six months may present petition (s.281) Corporate governance – Failure to hold statutory meetings, maintain books, and intra-company disputes as grounds for winding up Limitation – Time bar for contractual claims distinguished from creditors' rights in liquidation; secured creditor recognised Liquidation – Appointment of official liquidator; duties, powers and reporting (ss.294, 299–307)
8 October 2021
Summary judgment granted where defendants, served by publication, failed to seek leave to defend a mortgage-backed loan claim.
Civil procedure – Summary judgment under Order XXXV – service by publication – failure to apply for leave to defend. Security enforcement – mortgage and consent – sale of mortgaged properties upon default. Remedies – decretal sum, bank-rate interest from default to judgment, court-rate interest thereafter, costs.
8 October 2021
Application for mareva/interlocutory injunction dismissed for lack of locus, triable issue, irreparable harm, and unfavorable balance of convenience.
Commercial injunctive relief – mareva/interlocutory injunction – requirements: prima facie triable issue, irreparable harm, balance of convenience – necessity of locus standi and cause of action – documentary evidence required to prove ownership – public interest noted but not dispositive.
8 October 2021
Review to reopen dismissed commercial suit over newly discovered loan documents denied for lacking due diligence.
Commercial review – scope and limits – review is a restricted remedy, not a re‑hearing or appeal in disguise. Review grounds – discovery of new and important evidence – strict requirement of due diligence to locate/produce originals. Procedure – amendments to grounds require leave; court will not entertain unpleaded grounds raised in submissions. Evidence – digitisation of records does not automatically justify failure to produce originals on review. Procedural ignorance – unfamiliarity with new rules is not a sufficient ground for review.
8 October 2021
Arrest and detention refused where creditor had not exhausted execution against collateral and no bad faith shown.
Execution — arrest and detention as civil prisoners — requirement to show judgment debtors acted in bad faith or obstructed execution — creditor must first exhaust remedies against available collateral — prior filings before decree not necessarily obstructive.
7 October 2021
Leave to appeal granted where High Court’s handling of competency, hearing rights and prior proceedings raised arguable issues.
Arbitration – registration of arbitral award – leave to appeal – discretion to grant leave – requirement of arguable grounds – right to be heard – suo motu jurisdictional determinations; relevance of prior proceedings and pending appeals.
6 October 2021
A prior withdrawal without leave bars re-filing similar proceedings; renewed objection dismissed as abuse of process.
Civil Procedure — Order XXIII Rule 1(3) CPC — withdrawal without leave to re-file bars subsequent identical applications; jurisdictional and preliminary objection; abuse of court process; resubmission of objection proceedings; subsistence of withdrawal order.
5 October 2021
Application for extension to file a witness statement dismissed for failure to account for delay and insufficient cause.
Civil procedure – Extension of time – discretionary equitable remedy – applicant must account for every day of delay and show diligence (Lyamuya; Bushiri). Insufficient cause – unsupported claims of travel/self-isolation and counsel unavailability do not justify extension. Requirement for documentary proof where travel/self-isolation is relied upon. Court may impute negligence where applicant sits idle until the deadline.
5 October 2021
Court granted leave to appeal on arguable points of law under the Arbitration Act and denied costs.
Arbitration Act s.74(4) – leave to appeal; Appellate Jurisdiction Act s.5(1)(c) – leave requirement; Leave discretionary – requires point of law or public importance; Authorities: BBC v Ng'imaryo; Rutatigana – test for granting leave; Costs – leave applications not routinely awarded costs against respondent.
1 October 2021
Court recorded the parties’ settlement as a decree and awarded costs to the plaintiff because the defendant paid only after suit was filed.
Consent judgment — Deed of Settlement filed under Order XXIII Rule 3 accepted and recorded as Court decree; Costs — discretion under section 30 Civil Procedure Act; Costs normally follow the event — defendant who compelled litigation by delayed payment liable for plaintiff's costs; Taxation of costs where parties settle principal but not costs.
1 October 2021
Whether late‑filed additional documents and notices to produce without leave breach the scheduling order or constitute abuse.
Civil procedure — scheduling orders and departure (Order VIII r.23); production of documents — Order VII r.14/18 and Order XIII r.1–2; notices to produce governed by Evidence Act s.68 not time‑limited by CPC; abuse of court process — scope and test; late list of documents expunged for lack of leave.
1 October 2021
Extension of time granted to file arbitral award because delay was caused by the arbitrator, not the applicant.
Arbitration — extension of time to file arbitral award for registration — whether delay attributable to arbitrator or applicant — duties of arbitrator to notify and to file award (Arbitration Act/Rules) — application of Lyamuya factors in granting extension.
1 October 2021
Failure to prove issuance of an SBLC in required form negates security-sharing and voids related securities; defendants’ counterclaims dismissed.
Banking law – standby letter of credit (SBLC) – condition precedent to drawing under foreign facility – absence of SBLC in form and substance voids Security Sharing Agreement and securities; security agent v. lender; foreign loan registration and documentary proof of underlying trade documents.
1 October 2021
Failure to issue the SBLC in the agreed form and substance rendered the security documents void and counterclaims dismissed.
Banking and finance – Structured trade loan – Condition precedent requiring SBLC/LC in form and substance; non‑issuance nullifies security architecture; Mortgages, debentures and guarantees held to secure a non‑existent SBLC are void; Role of local bank as security agent distinguished from lender; Foreign loan registration (Bank of Tanzania) – policy observations (obiter).
1 October 2021