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.

37 judgments
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37 judgments
Citation
Judgment date
August 2023
Applicant entitled to repayment with contractual and penal interest despite mortgage being void; loan remains repayable.
Commercial law – loan repayment – mortgage declared void ab initio – unsecured loan still repayable; contractual interest and penal (default) interest enforceable where agreed in facility letter.
30 August 2023
Plaintiff failed to prove novation invalid or that bank lacked right to enforce mortgaged securities; suit dismissed.
Commercial law – mortgage enforcement; deed of novation – transfer of bank assets and rights; standing to enforce mortgages after acquisition; burden of proof on alleged invalidity of novation; ex parte hearing; dismissal for want of prosecution (counterclaim).
29 August 2023
Transfer and sale of pledged shares set aside for forgery of the transfer form; sold shares ordered returned with damages and costs.
Securities — validity of transfer of pledged shares; alleged forgery of transfer documentation. Evidence — forgery proven by circumstantial evidence; civil standard for fraud and its application. Procedure — compliance with CSD/R and brokerage procedures; significance of documentary inconsistencies (dates, stamps, signatures). Remedies — declarations of nullity, restitution of shares, general damages and costs.
29 August 2023
Court recorded a lawful deed of settlement as a consent judgment and decree, marking the suit settled.
Civil procedure – Order XXIII Rule 3 CPC – Deed of settlement – Court to record lawful agreement and pass decree – Consent judgment and decree – Settlement adjusts suit in whole – Consent decree not appealable.
29 August 2023
A debtor’s recognition and settlement negotiations can revive a time‑barred arbitral award, permitting its registration.
Arbitration — registration of arbitral awards — extension of time to register an award previously time‑barred. Civil procedure — effect of dismissal for limitation — functus officio and available remedies (review/appeal). Contract law — s.25(1)(b) Law of Contract Act — debtor's recognition/undertaking can revive time‑barred obligations. Execution — revival of limitation by settlement negotiations permitting registration and execution of award.
29 August 2023
Plaintiff proved loan, valid securities (including mortgage), defendants' default; judgment for outstanding debt, interest, sale remedy and costs.
Banking and security – loan facility and facility letters – personal guarantees and legal mortgage – validity of spousal consent for mortgage of matrimonial home – default and contractual remedies; award of decretal and post-judgment interest and authorization to sell mortgaged property.
28 August 2023
Proprietor personally liable for business loans; securities valid; bank awarded TZS 1,154,423,519.39 plus interest and costs.
Banking law – loan facilities and consolidation; Business name liability – sole proprietor personally liable; Securities – registered mortgages, hypothecation and guarantees; Evidence – weight of bank records and non-production of attesting officer; Remedies – decree for proven sum, commercial and post-judgment interest, realization of securities.
28 August 2023
25 August 2023
Court declared the bank’s larger claimed outstanding loan exaggerated and ordered immediate payment of the reconciled TZS 291,963,215.78 with interest from judgment.
Commercial law – Loan restructuring and repayment; disputed outstanding balance; admissibility and weight of bank statements and restructure letters; whether early demand for arrears amounts to contractual breach; measurement and awarding of outstanding principal and interest.
25 August 2023
Clearing agent breached agency duties and acted fraudulently by under‑declaring taxes, entitling the plaintiff to compensation.
Contract law – agency – existence of principal–agent relationship established by invoices, agency fees and bank transfer evidence. Contract breach – agent’s failure to remit taxes it invoiced for constitutes breach of contractual duties. Fraud – submission of false customs documents and forged deposit slips; admission in tax proceedings supports fraud finding. Damages – plaintiff entitled to compensation for taxes paid and general damages; invoices alone insufficient to prove specific payment.
25 August 2023
Notice of appeal does not bar taxation; instruction fee recalculated under correct Ninth Schedule item.
Taxation of costs – jurisdiction after notice of appeal – notice of appeal does not oust High Court jurisdiction to tax costs; right to be heard – presence of representation satisfies audi requirement; Advocates Remuneration Order – correct application of Ninth Schedule (item 6 for claims TZS70m–150m) for instruction fee; Eighth Schedule item 3 – court attendance charges (TZS50,000 per 15 minutes).
23 August 2023
Procedural 2020 amendments require joinder of the Attorney General; non-joinder renders pending suits incompetent.
Government Proceedings Act (2020 amendments) – procedural amendments retrospective – mandatory joinder of Attorney General as necessary party after statutory notice – non-joinder vitiates proceedings – statutory notice prerequisite cannot be bypassed by amendment – suit struck out as incompetent; filing fees to be carried over.
18 August 2023
Electronic submission alone is insufficient; filing occurs on the date of fee payment, so a one-day late reference was dismissed.
Advocates' Remuneration Order – filing of reference – whether filing date is electronic submission date or date of payment/control-number generation; Electronic Filing Rules – submission does not replace payment requirement; Time limits – one-day delay cannot be condoned without procedure; Public holiday excuses and JSDS2 availability.
18 August 2023
Default judgment granted for unpaid loan; decree execution conditioned on newspaper publication and waiting period.
Commercial law – Banking – Loan facility – Recovery of outstanding loan where borrower and guarantors default – Default judgment under Rule 22 (High Court Commercial Division Procedure Rules). Civil procedure – Default judgment – sufficiency of affidavit evidence including authentication of electronic documents – procedural compliance with Rule 22. Remedies – decretal amount, interest, costs and conditional execution pending publication under Rule 22(2).
17 August 2023
The plaintiff's contract claim accrued at employment termination and, being filed after six years, was time-barred and dismissed.
Limitation of actions – contract claims – accrual of cause of action upon first default; Law of Limitation Act (Sections 5, 7; Item 7 Part I) – six‑year period; time‑barred suits deprive court of jurisdiction; parties bound by their pleadings.
17 August 2023
Facility letter authorizing direct payments defeated claim of unauthorized withdrawals; plaintiff failed to prove loss and suit dismissed with costs.
Banking law – banker–customer relationship – alleged unauthorized withdrawals – whether facility letter authorises direct payments to beneficiaries. Contract interpretation – facility letter terms permitting direct payments and allocation of fees and charges. Evidence – burden to controvert bank records and produce contemporaneous documents (e.g., cheque books) to show unauthorized transactions. Civil standard – balance of probabilities; uncontroverted bank evidence prevails.
17 August 2023
Default judgment entered for the applicant after respondents failed to defend; refund, interest, damages and costs awarded.
Commercial Division – Default judgment – Substituted service by publication – Compliance with Rule 22 (Form No.1 and affidavit) – Reliefs: restitution of purchase price, contractual and court interest, general damages, costs – Conditional non-execution pending publication.
14 August 2023
A foreign plaintiff without sufficient Tanzanian immovable property was ordered to provide security for costs of USD 36,623.9.
Security for costs — Order XXV Rule 1(1) CPC — foreign plaintiff lacking sufficient immovable property in Tanzania — quantum guided by Advocates Remuneration Order (3% of liquidated claim) — reasonableness of proposed security.
14 August 2023
Unfair-prejudice petition under the Companies Act was settled by consent; court recorded and incorporated the Deed of Settlement as its decree.
Companies law – Unfair prejudice petition under s.233 – parties settled by Deed of Settlement. Civil procedure – Order XXIII r.3 CPC – consent settlements recorded as consent decisions/decrees. Consent decree – court’s role limited to examining enforceability and recording settlement.
11 August 2023
Eviction granted to bona fide purchaser where alleged execution-stage irregularities must be challenged separately.
Execution of decree – sale by auction – absoluteness of sale under Order XXI (rules 87–92) – eviction of purchaser – alleged auction irregularities (Auctioneers Act s.12(2), Land Act s.113) must be challenged by application to set aside sale or separate suit, not in eviction proceedings.
11 August 2023
Court ordered shareholders meeting to update BRELA records and appoint directors where quorum was impossible due to deceased directors.
Companies Act s.137 – Court-ordered convening of shareholders meeting – Updating company records at BRELA via ORS – Appointment of directors where quorum impossible due to deceased directors – Urgent and unopposed applications.
9 August 2023
Sickness proved by medical evidence and efforts to secure legal representation justified extension of time to apply to set aside ex-parte orders.
Civil procedure – extension of time – sickness and proof by medical certificate as sufficient ground for condonation. Civil procedure – extension of time – difficulty in obtaining legal representation by a lay litigant as a legitimate ground to grant extension. Condonation – applicant must account for period of delay; balance of probabilities test applies.
7 August 2023
A lawful Deed of Settlement between the plaintiff and defendants was recorded and entered as the court's decree.
Commercial law – contract for sale of goods (coffee) – claim for payment, refund, interest and damages; settlement by Deed of Settlement – consent judgment – recording settlement as decree under Order XXIII rule 3 Civil Procedure Code (Cap.33 R.E.2019).
7 August 2023
Withdrawal with leave to refile does not extend limitation; time‑barred suit dismissed with costs.
Limitation of actions – Withdrawal with leave to refile – Order XXIII rule 3 CPC – leave to refile does not extend or waive statutory limitation – time‑barred suit must be dismissed; non‑joinder objection not considered.
7 August 2023
Default judgment for bank on unpaid consumer loan; contractual and post-judgment interest awarded; publication required before execution.
Commercial law – Default judgment under Rule 22(1) – substituted service by publication – sufficiency of affidavit proof of indebtedness (Evidence Act ss.110–112) – bank loan repayment obligations – contractual interest and post-judgment interest – publication condition before execution (Rule 22(2)).
4 August 2023
Default judgment for unpaid consumer loan after lawful substituted service and proof under Rule 22(1).
Commercial law – Default judgment – Requirements of Rule 22(1): proof of service, Form No.1, affidavit in proof of claim and authenticated exhibits. Civil procedure – Substituted service by publication where personal service fails. Contract law – Breach of consumer loan facility; obligation to perform under Law of Contract Act s.37. Remedies – Award of principal, contractual interest to judgment, post-judgment interest at court rate, costs. Execution – Conditional execution and publication requirement under Rule 22(2).
4 August 2023
Suit against the East African Community barred by immunity; court dismissed claim for lack of jurisdiction.
Immunity of international organisations – East African Community – Headquarters Agreement Article IV(1)(a)-(b) – immunity of Secretariat, property and assets – waiver limitations – jurisdictional bar to suit.
4 August 2023
Applicant failed to account for unexplained delay and did not show an apparent illegality justifying extension of time.
Limitation of actions — extension of time — applicant must account for each day of delay; alleged illegality must be apparent on the face of the record to justify extension — award of general damages is discretionary and not per se illegal.
4 August 2023
Applicant granted interim maintenance of status quo and injunctions restraining respondent’s termination notice and usurpation pending trial.
Civil procedure – interim relief – maintenance of status quo ante and interim injunctions – requirements: prima facie case, irreparable harm, balance of convenience; hearsay evidence – expunging unsupported third‑party averments; contractual disputes – validity/effect of termination notice pending trial.
4 August 2023
Reference dismissed; taxing officer correctly taxed attendance and instruction fees and instruction fee was not excessive.
Advocates’ Remuneration Order – Attendance fees (Eighth Schedule, Item 3) are distinct from instruction fees; Counterclaim treated as separate suit for taxation; Taxing officer’s discretion in assessing instruction fees and applying Ninth Schedule scales will not be disturbed absent injudicious exercise or wrong principle.
4 August 2023
A petition under Companies Act s233(1) is a suit (six-year limitation); preliminary objections (limitation, non-joinder, verification, majority status) were overruled.
Companies Act s233(1) – nature of petition (suit vs application) – applicable limitation period; Law of Limitation Act – Item 24 (six years) vs Item 21 (60 days); non-joinder – BRELA – not a pure point of law for preliminary dismissal; verification defects – amendable; unfair prejudice petitions – available to majority and minority shareholders.
4 August 2023
Summary judgment granted for unpaid electricity arrears after valid publication service and failure to seek leave to defend.
Summary procedure (Order XXXV) – service by publication – affidavit of inability to locate defendant – allegations deemed admitted where no leave to defend filed – entitlement to judgment for proven electricity arrears – post-judgment interest at court rate.
4 August 2023
Court overruled objections, permitting plaintiff’s contract claim to proceed despite apparent third‑party agreement.
Civil procedure – Preliminary objections – court may examine pleadings and annexures when objection is not purely abstract; Cause of action – plaint and annexures to be read together; Locus standi – where contract appears with third party, factual nexus may require evidence; Objections overruled where resolution requires trial evidence.
3 August 2023
An award transmitted to court by letter is incompetent if not accompanied by the arbitral proceedings required under Regulation 51(5).
Arbitration — Recognition vs enforcement of awards; Regulation 51(5) — transmittal of award must include arbitral proceedings; Regulation 63(1) — petition requirement is subject to exceptions; Incompetent application (award without proceedings) — struck out with leave to re-file.
3 August 2023
An award filed under Regulation 51(5) must be accompanied by the full arbitral proceedings; noncompliance renders filing incompetent.
Arbitration — Filing of arbitral award — Regulation 51(5) requires award to be filed together with arbitral proceedings; mandatory requirement — Regulation 63(1) (petition requirement) subject to "save as otherwise provided" — Recognition (s.83) and enforcement (s.73) of awards — Incompetent filing struck out with leave to refile.
3 August 2023
Applicants failed to show arguable or important issues; leave to appeal is dismissed with costs.
Leave to appeal – discretionary and not automatic – applicant must show arguable issue of law or fact of sufficient importance or novel point of law; High Court not to determine merits; extension of time – promptness and accounting for delay; alleged illegality as ground for extension.
2 August 2023
1 August 2023