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.

307 judgments
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307 judgments
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Judgment date
December 2024
A Court of Appeal stay remains effective until varied or rescinded unless it expressly states it will lapse on default.
* Civil procedure – Stay of execution – Effect of Court of Appeal stay conditioned on furnishing security – Whether stay lapses automatically on default to furnish security – Rule 64(2) Court of Appeal Rules, 2009.
20 December 2024
Failure to file proof of debt requires a secured creditor to surrender its security for the benefit of all creditors.
Companies (Insolvency) Rules — Proof of debt (Form 365a) — Rule 148(1)–(3) — Rule 170(1) — Omission by secured creditor to disclose security — Surrender of security for benefit of all creditors — Liquidator’s entitlement to custody of title deed.
19 December 2024
Refiling without impleading the tax authority is not automatically an abuse nor mandates joinder as a necessary party.
Civil procedure – Joinder of necessary parties – Order II Rule 1 – Necessary party versus evidentiary convenience; Civil procedure – Abuse of court process – Withdrawal with liberty to refile – dominus litis and absence of mandatory court direction to implead a party.
19 December 2024
13 December 2024
A judgment debtor must satisfy the decree or obtain an appellate stay to halt execution; third‑party interests do not bar attachment.
* Execution proceedings – requirement to satisfy decree or obtain appellate stay to halt execution – pending review insufficient without stay or satisfaction. * Execution – attachment and prohibitory orders may issue despite alleged third‑party interests; third parties may lodge objections subsequently. * Procedure – valuation reports required before proclamation of sale.
13 December 2024
Applicant entitled to principal and interest for breach of deed of settlement; cryptocurrency dealings not per se illegal.
* Contract law – validity of deed of settlement – cryptocurrency transactions not per se illegal and do not vitiate contracts. * Breach of contract – admitted misappropriation and failure to honour repayment instalments. * Remedies – award of principal and interest; no costs awarded. * Burden and standard of proof – civil standard (balance of probabilities) applied.
13 December 2024
Court refused to record alleged part-payment absent certification or proper Order XXI rule 2(2) application, gave 14 days to comply.
* Civil Procedure – Execution – Order XXI rules 2(1)-(3) – Requirement that payments or adjustments be certified by decree holder or recorded after application under rule 2(2). * Evidence – Alleged part-payment – insufficiency of unauthorised computer statements and handwritten totals to prove payment. * Procedural compliance – judgment debtor’s duty to follow Order XXI rule 2(2) to have unacknowledged payments recorded.
12 December 2024
Applicant bank entitled to Tshs.3,092,913,885, general damages and interest for defendants’ loan default.
Commercial law – loan facilities – validity and enforcement of credit facility agreements; Security – mortgage, chattel mortgage and personal guarantees; Breach of contract – default and entitlement to principal, damages and interest; Decretal execution – publication condition under Rule 22(2).
10 December 2024
Plaintiff proved default; guarantors jointly and severally liable for outstanding loan; judgment interest, costs, and publication conditions imposed.
* Commercial law – debt recovery – default judgment based on affidavit evidence and secondary documents admissible under Evidence Act s.68(f),(g). * Guarantees and indemnities – guarantors jointly and severally liable for outstanding loan after mortgage sale. * Mortgage enforcement – sale proceeds insufficient to discharge debt; deficiency recoverable. * Interest on judgment – awarded at 7% from date of judgment. * Procedure – substituted service by publication and statutory publication/waiting period before execution (Rule 22(2)(a)).
6 December 2024
Illegality in an arbitral award can justify extension of time despite the applicant's inordinate delay.
* Extension of time – application to challenge arbitral award – requirements for extension: accounting for delay, diligence and sufficient cause. * Illegality – allegations of illegality (including jurisdictional issues) in an arbitral award can constitute sufficient cause for extension. * Arbitration – registration and challenge of arbitral awards – time limits and discretion under the Law of Limitation, Arbitration Act and HCCD Rules. * Procedural diligence – unexplained, inordinate delay may be weighed against alleged illegality when exercising discretion.
6 December 2024
Court sanctioned discounted share issuance under Companies Act s60, imposing a 90‑day completion limit and CMCA extension requirement.
Companies Act s60 – issuance of shares at discount – requirement of court sanction – members’ resolution – CMCA approval and listing – one‑year operation requirement – court may impose time limit and require regulatory extension.
5 December 2024
November 2024
Six-day delay in filing defence condoned due to advocate’s bereavement and prompt subsequent action; ten-day extension granted.
Commercial procedure – extension of time to file written statement of defence – Rule 20(2) High Court (Commercial Division) Procedure Rules – section 93 CPC – sufficiency of cause and accounting for each day of delay – relevance of Lyamuya and Bushiri – bereavement and travel as acceptable cause.
29 November 2024
Escrow/internal accounts represented disbursement by respondents; borrowers defaulted; respondents awarded USD 47,228,592.53 plus interest and costs.
• Banking law – syndicated/club loan facilities – disbursement via internal/escrow accounts and effect of restructurings. • Evidence – burden of proof in civil cases (Section 110 Evidence Act) and adverse inference for failure to call material witness. • Company law – proof of corporate existence (certificate of incorporation) and limits of inferring legal personality. • Contract law – valid irrevocable payment instructions; parties' obligations to perform; default and enforcement of securities. • Remedies – quantification of outstanding loan, contractual interest and court interest.
29 November 2024
The plaintiff’s specific-performance claim over a land sale is a land dispute; the Commercial Division lacks jurisdiction.
Jurisdiction — Commercial Division v Land Courts; conveyancing and sale of land; specific performance of land sale; Section 167 Land Act Cap 113; Section 3 Land Dispute Courts Act Cap 216; High Court (Commercial Division) Procedure Rules, Rule 3.
29 November 2024
A committing court may release a civil prisoner on serious medical grounds proven by adequate medical records.
Civil Procedure – Execution – Arrest and detention of judgment debtor – Release of civil prisoner on ground of serious illness under s.47(3)(b) CPC; sufficiency of medical evidence (MRI reports and treatment records); distinction between committal and release; burden on decree-holder to rebut medical evidence.
22 November 2024
Plaintiff failed to prove execution of a loan agreement; unsigned offer letter insufficient, suit dismissed with costs.
Contract law – offer and acceptance – requirement of communication/production of acceptance; evidence – burden of proof (he who alleges must prove) – unsigned offer letter insufficient to prove a binding credit facility agreement; injuria sine damnum – loss without legal remedy; suit dismissed with costs.
22 November 2024
Applicant’s bid for a court broker dismissed as barred by prior ruling and respondents’ admitted compliance.
Commercial injunction — execution — appointment of court broker to verify compliance — prior identical prayer refused — functus officio, res judicata and issue estoppel — failure to file counter‑affidavit admits respondents’ factual averments — need for evidence of disobedience before enforcement.
22 November 2024
A defendant’s purported "cross suit" was a time‑barred set‑off, expunged and preliminary objection upheld.
Civil procedure — Distinction between set‑off and counterclaim; set‑off requires pleading within 21 days under Order VIII r.6(1); counterclaims treated as cross‑suits under Order VIII r.9(2); amendment beyond court’s leave and time‑barred set‑off liable to dismissal and expungement.
22 November 2024
Tanzanian court recognized and enforced a Dubai commercial judgment after upholding jurisdiction and email/bilingual service.
Enforcement of foreign judgments — common law doctrine of obligation — presumption of competence under CPC s.12 — forum selection clauses and court jurisdiction — service by email and bilingual notification — waiver of right to be heard — finality and specific monetary sum — narrow public policy exception.
15 November 2024
A director who misappropriated the applicant's loan funds was ordered to refund them with interest, damages and costs.
* Company law – Director's fiduciary duties – breach by misappropriation of company funds (s182 Companies Act). * Civil procedure – Default judgment – substituted and electronic service; failure to file written statement of defence or counter-affidavit. * Remedies – declaration, refund of misappropriated sums, specific and general damages, interest and costs. * Evidence – affidavit and documentary exhibits as substitute for oral evidence in default proceedings.
15 November 2024
Court lacks jurisdiction to extend time for filing defence after 28 days; plaintiff may seek default judgment.
* Commercial Court procedure – extension of time to file Written Statement of Defence – statutory 21-day filing period and seven-day grace period – 28-day jurisdictional limit under Rule 20(2). * Relief – default judgment permitted where no timely defence is filed. * Procedure – applications for extension ordinarily by chamber summons supported by affidavit (Order XLIII Rule 2, CPC).
15 November 2024
Plaintiff obtained default judgment against defendant for unpaid supply of goods with interest and damages.
Contract law – sale on credit; breach for non-payment of supplied goods; default judgment after substituted service; affidavit proof and absence of counter-affidavit; commercial interest and court interest; award of general damages; conditional execution under Rule 22(2).
15 November 2024
Plaintiff failed to prove a valid contract or underlying loan; suit dismissed and costs awarded to defendant.
Contract law – existence and certainty of contract; requirement to prove underlying transaction giving rise to settlement agreements; adverse inference for failure to call material witnesses; pleadings and exhibits must be consistent; where agreement’s object is uncertain it is void.
15 November 2024
A separate injunction application is permissible; argumentative or conclusory affidavit paragraphs are expunged and respondents pay 75% costs.
Companies law/Commercial procedure – interlocutory injunction – permissibility of separate interlocutory application where main petition lacked restrictive prayers; Civil Procedure – affidavits – inadmissibility of legal arguments, conclusions or prayers in affidavits (Order XIX r.3(1)); expunction of offending paragraphs; costs where preliminary objections are largely misconceived but partly meritorious.
15 November 2024
Taxing Officer may award same instruction fees in Advocate‑Client bill when Party‑Party amount upheld; court will not reopen settled taxation.
Advocates’ costs – Taxation of instruction fees – consistency between Party‑Party and Advocate‑Client bills; Taxing Officer’s discretion – interference only where injudicious or wrong principle applied; burden of proof in disputed payment of legal fees; functus officio and issue estoppel bar re‑litigation of taxation issues; pending appeal does not nullify binding High Court confirmation unless reversed.
15 November 2024
Court grants 30-day extension to challenge arbitral award, finding delay technical rather than inordinate.
Law of Limitation — extension of time under s.14(1) — technical delay vs inordinate delay — withdrawal with leave to refile — alleged illegality of arbitral award — limitation for filing arbitral awards (60 days).
15 November 2024
Court recognised and enforced an uncontested domestic arbitral award after finding arbitrability and no public policy conflict.
* Arbitration — Recognition and enforcement of domestic arbitral award under Arbitration Act — Section 83(2) public policy and arbitrability ex officio tests. * Arbitrability — contractual dispute over public works road-upgrading contract — arbitrable. * Public policy — narrow exception; enforcement refused only where violation of basic notions of morality and justice. * Decree extraction — court may extract dispositive orders from award and register them as court decree. * Costs — allocation of arbitration institutional fees and party legal costs.
14 November 2024
Whether the executing court may construe a decree from a consent judgment adopting a settlement and permit the applicant's execution.
* Civil procedure – Execution of decrees – Decree extracted from consent judgment adopting a deed of settlement is executable. * Civil procedure – Construction of decrees – Executing court may refer to judgment and proceedings to ascertain decree’s true meaning. * Civil procedure – Execution timing – Agreement to pay by instalments does not bar execution after agreed time has expired; conditional third‑party payments do not suspend execution. * Execution remedies – Recording partial satisfaction and prohibiting third‑party payments pending execution.
13 November 2024
Extension of time granted where appeal delay was technical (court transcript omission) and applicant acted diligently.
Appellate procedure – extension of time under s.11(1) AJA; technical delay vs actual delay; accounting for delay and diligence (Lyamuya criteria); litigant not punished for court/transcription errors; semantic form of prayers (enlarge vs extend) not fatal.
8 November 2024
Whether execution by possession of mortgaged property is permitted under a consent decree varied by deed of variation.
* Civil procedure – execution of consent decree – deed of settlement and deed of variation – deed of variation fixing decretal amount and preserving other terms allowing execution against mortgaged property. * Civil procedure – preliminary objections – factual disputes (amount paid/outstanding) not to be determined by PO (Mukisa principle). * Government Proceedings Act – s.6(2) and (5) – inapplicable where no government interest or proper joinder of Attorney General exists. * Execution – permitted modes include entering possession of mortgaged property where contractually agreed.
8 November 2024
A Tanzanian court may grant interim injunctions to protect rights pending foreign-seated CIETAC arbitration when jurisdiction and Attilio tests are met.
Arbitration – Interim reliefs – Jurisdiction of national courts to grant interim injunctions in support of arbitration (section 2(3) JALA; sections 51, 7 Arbitration Act) – Party autonomy and seat of arbitration – Mareva/prohibitory injunction pending CIETAC arbitration – Attilio v Mbowe trinity applied.
8 November 2024
Court dismissed challenges to domestic arbitral awards: public‑policy, jurisdiction and merits objections failed.
Arbitration — setting aside awards — sections 74, 75, 80 Arbitration Act — public policy (procurement rules vs. manner of procurement) — choice of curial law — Kompetenz‑Kompetenz — waiver by participation — separability doctrine — limits of judicial review (no merits re‑hearing).
8 November 2024
Court reduced excessive instruction fee and disallowed misclassified taxation costs; each party bears own costs.
• Taxation of costs – proper schedule for instruction fees – distinction between liquidated and unliquidated claims – application of 11th Schedule item (d) for defendants defending unliquidated claims. • Taxing officer’s discretion – fees must be commensurate with time, energy and industry; appellate interference limited to cases of judicial error. • Order 48 – effect of disallowance exceeding one-sixth of a bill of costs. • Classification of costs – bill of costs versus fee for attending taxation (Order 55(3)).
8 November 2024
Extension of time to set aside dismissal denied for failure to account for delay and lack of proof of timely filing.
Civil procedure — Extension of time under Section 14 Law of Limitation Act and Order VIII r.20(2) CPC; requirements to account for all days of delay (Lyamuya factors); illness of counsel as potential cause; necessity of documentary proof for alleged timely electronic filings and registry rejections.
8 November 2024
Court recorded parties' settlement as consent judgment: defendants to pay USD 80,000 in quarterly instalments, enforceable on default.
* Civil procedure — Consent judgment — Recording a deed of settlement as court decree under Order XXIII Rule 3 CPC and High Court (Commercial Division) Procedure Rules. * Enforcement — Payment schedule in settlement; instalment payments; specified bank remittance. * Execution and remedies — Default entitles plaintiff to execute and claim remaining balance plus 25% penalty. * Finality — Full performance extinguishes plaintiff’s claims and restores pre-litigation positions.
8 November 2024
A filed deed of settlement was recorded as a consent judgment enforcing repayment, business resumption, and recovery obligations.
Consent judgment – Recording and adoption of deed of settlement – Enforcement of repayment schedule – Resumption of business relationship – Obligation to pursue recovery of funds from fraudulent account – Remedy on default (acceleration to original claim).
8 November 2024
Plaintiff failed to prove existence or breach of contract; suit dismissed and defendant awarded costs.
Contract law – proof of written or oral contract – inference from conduct; evidentiary value of invoices and EFD receipts; burden of proof; failure to call material witnesses; dismissal for want of merit; costs awarded.
1 November 2024
A judgment debtor may waive s.48(1)(e) protection by encumbering or offering a dwelling as security, making it attachable.
* Civil Procedure Code s.48(1)(e) – protection of residential dwelling; waiver by encumbrance or offering as security; judgment debtor's undertaking in stay of execution; attachment and sale in execution; interplay with Land Act provisions; reliance on Ngeleja v National Bank of Commerce.
1 November 2024
Extension of time to refile a dismissed time‑barred arbitration registration was refused due to res judicata, functus officio and unexplained delay.
* Arbitration — limitation — applicable period for Arbitration Act matters (Item 21 Part III Law of Limitation Act — 60 days). * Extension of time — discretionary relief — requirement to account for all delay, diligence and absence of inordinate delay. * Res judicata / functus officio — a court cannot grant extension to re‑file a matter it has already dismissed; remedy is review. * Technical delay — time spent prosecuting earlier court proceedings may be excusable but must be adequately accounted for.
1 November 2024
Court recorded parties' settlement as a consent judgment ordering the defendant to pay USD 145,000 by a set date.
Commercial dispute — consent deed — recording as consent judgment under Order XXIII Rule 3 CPC and High Court (Commercial Division) Procedure Rules; settlement terms enforceable as consent decree; payment, default and execution; confidentiality and no admission of liability.
1 November 2024
October 2024
Oral last‑minute extension refused; unserved witness statement struck out for unexplained delay under Rule 55.
HCCD Procedure Rules — service of witness statements — Rule 49 and Rule 55 — failure to serve within prescribed time — striking out witness statements unless court extends time; extension of time applications require formal application, evidence and accounting for each day of delay; oral applications on trial date permitted only in genuine emergencies.
25 October 2024
Whether a taxing officer improperly exercised discretion in awarding instruction, attendance and filing fees under the Advocates Remuneration Order.
* Taxation of costs – Advocates Remuneration Order (GN No. 263 of 2015) – instruction fees, attendance fees and filing fees – requirement to give reasons – taxing officer’s discretion – appellate interference standard (Mbogo test).
25 October 2024
Court recorded parties’ settlement under Order XXIII(3) CPC and made the deed a decree enforceable on default.
• Civil procedure – Consent judgment – Recording a filed deed of settlement under Order XXIII(3) CPC – Deed incorporated as court decree and enforceable on default; payment schedule; release of liability; costs each party.
25 October 2024
Application for discovery under Order XI r.10 refused where possession not shown and request amounted to a fishing expedition.
Order XI r.10 CPC — Discovery of documents — five‑part test: parties before court; pending issues; relevance; possession/power; no fishing expedition — pre‑trial discovery refused where possession not established and request seeks plaintiff’s evidentiary material.
25 October 2024
A court lacks jurisdiction to extend the defendant’s time to file a defence after the 28‑day statutory period; default judgment permitted.
* Civil procedure — Commercial Court Rules — Rule 20(2): defendant must file written statement of defence within 21 days or apply for extension within 7 days after expiry (maximum 28 days). * Jurisdiction — Court lacks power to extend time after the statutorily fixed 28‑day period. * Good cause — internal negligence or document misplacement does not ordinarily constitute sufficient reason for extension absent supporting evidence. * Default judgment — plaintiff entitled to apply under Rule 22 where defendant misses prescribed timelines.
25 October 2024
Court entered consent judgment enforcing a settlement with monthly payments, 15% default interest and execution on default.
Commercial law – Consent judgment – Recording and entry of judgment by consent based on a filed Deed of Settlement; Payment schedule and enforcement; Interest on default; Full and final release of claims; Costs.
23 October 2024
Where more than one-sixth of a bill is disallowed, the party loses costs of taxation; that award was set aside.
Advocates Remuneration Order (GN No. 263/2015) — Rule 48; taxation of bills of costs; meaning of “more than one-sixth disallowed” — denial of costs of taxation (incidental costs) where threshold exceeded; calculation of one-sixth exclusive of court fees; limits of Taxing Officer’s role.
18 October 2024
Default judgment for USD119,173.02 entered for plaintiff for breach of merchant services agreement where defendant failed to contest.
* Commercial law – Merchant Services and Indemnity Agreement – liability for disputed POS/card transactions; default judgment under Rule 22(1). * Civil procedure – substituted service by publication; consequences of failure to file defence or counter-affidavit; affidavits and annexures as evidence. * Remedies – quantum proven by bank statement; contractual/commercial interest and decretal interest; costs and conditional execution pending compliance with Rule 22(2).
18 October 2024
A registered trade mark owner obtained default judgment for infringement with injunction, destruction order and damages.
* Trade mark law – registered trade mark – exclusive right to use – Trade and Service Marks Act s.31 and s.32 * Infringement and passing off – similarity of mark, identity of goods, likelihood of confusion * Default judgment – uncontested affidavit evidence as substitute for oral evidence; failure to file defence treated as admission * Remedies – permanent injunction, destruction of counterfeit goods, award of general damages, execution under Commercial Court Rules (Rule 22)
18 October 2024
The court adopted the parties' settlement as a binding consent judgment and marked the contract dispute as fully settled.
Contract law – settlement – consent judgment – enforceability of mediation settlement – equipment sale disputes – recovery of outstanding amounts – enforceable deed of settlement – discharge of further claims on payment.
18 October 2024