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.

3,214 judgments
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3,214 judgments
Citation
Judgment date
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
Court granted extension to file set-aside application, finding illness and technical filing issues constituted sufficient cause.
Limitation of actions – extension of time – discretion under s.14(1) Law of Limitation Act and court rules; sufficient cause — sickness and family medical emergency; requirement to account for each day of delay; credibility of supporting documents; ICT/technical difficulties as acceptable ground for short delay.
18 October 2024
Procedural breach of Commercial Court page limits upheld but rectified under the overriding objective; amended submissions ordered with costs.
Civil procedure – Commercial Court Rules – Rule 66(2) and Rule 19(2) – page limit for written submissions – non-compliance. Civil procedure – Overriding objective – Article 107A(2)(e) and sections 3A/3B of the Civil Procedure Code – rectification vs expungement. Practice – appropriate remedy for procedural breaches – rejection/expungement versus opportunity to cure defect.
18 October 2024
A registered mortgage takes precedence over a tenant’s lease; objection to attachment dismissed; auction advertisement irregularity noted.
Execution; Order XXI Rules 57,59,60,61 CPC — tenant in possession — objection to attachment; Registered mortgage priority — Section 54 CPC; Attachment subject to registered charge; Proclamation of sale expiry and advertisement irregularity; Security-sharing agreements and proof of mortgage interest.
18 October 2024
Separate pleadings did not constitute admissions; unilateral statements cannot bind co‑defendants, so judgment on admission was dismissed.
Civil procedure — Order XII (judgment on admissions) — Whether separate written statements of defence constitute admissions — One defendant cannot admit on behalf of another — Acknowledgement of guarantee deed and credit limit not automatic admission to pay — Third‑party notice denying liability.
18 October 2024
Defective unsworn witness statements are nullities and cannot be amended; court struck them out and ordered ex-parte proof.
Evidence — Witness statements — Sworn witness statements must contain verification, jurat and be executed before a Commissioner for Oaths as per Commercial Division Rules; non-compliant documents are not statements and are nullities. Procedure — Amendment — Sworn evidence is not amendable; a nullity cannot be amended though proper sworn evidence may be supplemented or replaced; amendment after scheduling order requires leave/extension. Remedy — Incompetent witness statements to be struck out; where defence has no admissible evidence applicant may proceed ex parte.
17 October 2024
Suit for eviction-related damages stayed as res subjudice; jurisdiction and s.38(1) objections dismissed.
Commercial Division jurisdiction – scope and limits – admissibility versus jurisdiction; Civil Procedure Code s.38(1) – executing court’s exclusive domain over execution-related questions; Res subjudice (s.8 CPC) – overlapping parties and substantially identical issues bar subsequent suit; Preliminary objections on jurisdiction/res subjudice may be raised orally or at any stage.
17 October 2024
Court lifted the corporate veil to permit execution against directors after personal settlement undertakings were defaulted.
Company law – lifting corporate veil – execution of decree – deed of settlement creating personal director undertakings – default on instalments as ground to pierce veil; requirement to show lack of real separation and conduct to conceal assets or obstruct execution (Yusuph Manji v. Masanja).
16 October 2024
A plaintiff seeking default judgment must prove the substantive claim by affidavit; pleadings alone are insufficient.
Commercial law — Default judgment (Rule 22(1), Commercial Court Rules) — Plaintiff must prove substantive claim by affidavit. Evidence — Affidavit as substitute for oral evidence — Must state facts from personal knowledge or believed true and annex supporting documents. Civil procedure — Pleadings are not evidence; special damages must be specifically pleaded and strictly proved.
11 October 2024
Whether defendants breached a written sale contract by non‑payment — court held breach, awarding outstanding sum, interest and damages.
Contract law – Sale of goods – written contract, LPO and invoice as primary evidence; alleged partnership not proved – breach for non‑payment; remedies: decretal sum, commercial interest, general damages and costs.
11 October 2024
Foreign plaintiff lacking immovable Tanzanian property must provide security for costs; court ordered USD 20,000 deposit.
Security for costs – Order XXV Rule 1 CPC – foreign plaintiff without immovable Tanzanian property; movable property in dispute does not qualify; discretion as to quantum; necessary-party status does not preclude order.
11 October 2024
Dispute over post‑contract commercial use of an image was a commercial case; trial court misdirected by ignoring material contract, appeal allowed.
Commercial jurisdiction — definition of commercial case under section 2 MCA — contractual relationship and liability of business organisation arising from commercial activities; Evidence — duty to consider admitted exhibits — failure to consider material contract (Exhibit DI) is material misdirection; Privacy/likeness claims — burden to prove contractual limits, lack of consent and damage; General damages — cannot stand where liability and proof are defective.
4 October 2024
Electronic submission before midnight constitutes filing; later physical endorsement does not render the application time-barred.
Commercial procedure — electronic filing — meaning and timing of 'filing' under JALA (Electronic Filing) Rules 2018 (Rule 21) — electronic case file as official record — hard-copy presentation and Deputy Registrar endorsement not determinative of filing date — preliminary objection procedure.
4 October 2024
Arbitration clause in loan agreement held to cover related payment-agreement dispute; suit struck out for arbitration.
Commercial law – arbitration clause – extent of arbitral clause to subsequent related agreements; jurisdiction – court vs arbitration; preliminary objection – improper amendment and case‑management; striking out where arbitration agreement governs dispute.
4 October 2024
A stay under Order XXI Rule 27 requires a pending suit against the decree holder; application dismissed.
Civil Procedure — Stay of execution — Order XXI Rule 27 requires a pending suit against the holder of the decree; intended appeal against refusal to extend time to set aside an ex parte judgment is not a proper basis for stay; re‑filing same relief after Court of Appeal struck out prior application — abuse/delay; preliminary objection on point of law upheld.
4 October 2024
Extension of time granted to file notice of appeal due to alleged illegality despite a short unexplained delay.
Civil procedure – extension of time – illegality as sufficient reason for extension – failure to account for every day of delay – judicial notice of court records where annexures omitted.
4 October 2024
September 2024
Advocate’s illness or negligence does not constitute sufficient cause to set aside a default judgment; party must show good cause.
Civil procedure — Setting aside default/ex parte judgment — timeliness and filing date; payment/receipt as filing; advocates' illness or negligence not sufficient cause; party's duty to follow up; Rule 23(1) and 23(2)(b) HCCP Rules.
27 September 2024
Court dismissed objection to English pleadings absent Kiswahili translation, finding no prejudice and applicable English-language exceptions.
Language of proceedings – Interpretation of Laws Act s.84A and GN No.66/2022 – Whether English pleadings require Kiswahili translation under Rule 4(1)(a)&(b). Whether omission to file Kiswahili translation is fatal or causes prejudice – not fatal where parties are represented and documents are in English. Schedule items (finance/monetary affairs; governing law/practice in English) permit use of English in pleadings.
27 September 2024
Continuing-breach doctrine under Limitation Act prevents suit being time-barred for instalment loan; preliminary objection dismissed.
Limitation — contract claims — accrual of cause of action for instalment loan — Section 7 (continuing breach) of the Law of Limitation Act — fresh period of limitation runs while breach continues — preliminary objection on limitation overruled.
27 September 2024
Where an appeal challenges striking out of the suit, the appellate court, not the trial court, may grant preservatory orders such as a receiver.
Civil procedure – Appointment of receiver – Whether trial court may appoint receiver where underlying suit is struck out and appeal is pending – Appellate court’s jurisdiction to grant preservatory orders. Order XXXVIII Rule 1 and s.95 CPC – scope and limits when related appeal pending. Functus officio and sub judice considerations when proceedings are stayed or struck out.
27 September 2024
Application for extension to set aside a confirmed sale dismissed as overtaken by event and lacking sufficient cause.
Civil Procedure – Execution – Application to set aside sale – Right to apply exists before confirmation of sale under Order XXI r.90 – sale becomes absolute on confirmation. Extension of time – Sufficient cause – Illegality must be apparent on the face of the record (Lyamuya test) – absence of clear, immediately apparent illegality defeats extension. Execution – Valuation versus sale price – sale below valuation not automatically void; proclamation did not require court approval if price fell below valuation. Evidentiary contradictions – Self-contradictory affidavits weaken claims of procedural illegality.
27 September 2024
Court records parties’ deed of settlement as consent judgment, making agreed payments and release enforceable as a decree.
Commercial law – Consent judgment – Deed of settlement recorded under Order XXIII Rule 3 CPC – Settlement terms enforceable as decree – Execution on default – Full and final release; no admission of liability.
27 September 2024
A matrimonial home used by the applicant and family is not attachable and must be released from execution.
Civil procedure – Execution – Objection to execution – Matrimonial/residential home exemption under section 48(1)(e) CPC and Order XXI rule 57 – Burden to show property is non-attachable – Allegations of fraud in consent judgment not determinable in execution objections.
27 September 2024
Respondents permitted to amend reply to include BRELA documents only; new issues and belated annexures disallowed.
Civil procedure – Amendment of pleadings – Order VI r.17 – Court may allow amendment at any stage to determine real questions in controversy. Procedure – Oral application – Permissibility of oral application where circumstances justify. Companies law – Unfair prejudice petition – Scope of responsive pleadings vs cross-petition (counterclaim). Evidence/access to public records – BRELA documents retrievable by physical search may justify late inclusion. Pleadings – Afterthought annexures and new allegations (fraud/forgery) to be disallowed in amended reply.
27 September 2024
Application for interlocutory injunction dismissed: triable issues found but no irreparable harm and handover would pre-empt main suit.
Commercial law – Temporary injunction – Atilio test: prima facie case, irreparable harm, balance of convenience; monetary losses generally compensable by damages; interlocutory relief must not pre-empt main suit; capacity to sue issue raised but not formally decided.
27 September 2024
Pleadings can constitute notice by implication under s.68(b) Evidence Act, permitting admission of secondary documentary evidence.
Evidence Act (ss. 67, 68) – secondary evidence – admissibility requirements and the proviso to s.68. Notice to produce – when unnecessary: notice by implication arising from pleadings (s.68(b)). Documentary evidence – reliance on documents previously tendered in separate proceedings as basis for secondary evidence.
24 September 2024
Court may wind up a company on a bona fide special resolution and appoint the proposed liquidator.
Companies Act – Winding up – s.279(1)(a) – court-ordered winding up on special resolution – bona fide requirement against illegality or improper motive; Companies Act – Appointment of liquidator – s.294 – court may appoint liquidator proposed by petitioner; Voluntary winding up – advertisement and absence of objections; Necessity of liquidator to assume control to prevent standstill.
20 September 2024
Empanelment agreement valid but plaintiff failed to prove specific instruction, breach, or loss; suit dismissed, parties bear own costs.
• Contract law – validity of empanelment agreement; competency of signatories and ratification by addendum • Contract performance – requirement of written letter of undertaking under agreement and effect of oral instructions • Evidence – burden to prove contents of oral instruction and need for direct witness or corroborating documents • Breach and causation – dormant empanelment requires proved specific instruction before liability for negligent valuation arises • Remedies – failure to prove breach or loss defeats claims for compensation and interest
20 September 2024
Applicants’ demonstrated unit-title interests warranted release of the attached plot from execution.
Execution law – Objection under Order XXI Rules 57–59 CPC: requirement to show interest or possession at date of attachment; Unit Titles Act – statutory interests of unit owners in common property (including land); Registration of interests – registrable title persuasive but not invariably conclusive; Execution procedure – necessity to particularise unit titles in an execution application.
20 September 2024
Tanzanian court may grant interim injunctions in aid of foreign-seated arbitration and granted ex parte restraint on imports.
Arbitration — interim measures — jurisdiction of national courts to grant interim injunctions in aid of arbitration seated abroad — JALA s.2(3), Arbitration Act ss.51,7(3)(4) — party autonomy vs. facilitative role of forum courts — mareva-type injunction prior to commencement of arbitration — Atilio v Mbowe trinity applied.
19 September 2024
A foreign UAE judgment is enforced in Tanzania by an action on the debt with written evidence (witness statements) rather than a retrial.
Enforcement of foreign judgments – absence of reciprocal treaty – action on the debt at common law – procedure by written evidence (affidavits/witness statements) – witness statements admissible in lieu of affidavits – retrial barred by res judicata and forum-selection.
13 September 2024
A valid LCIA arbitration clause requires court referral to arbitration; court retains jurisdiction but enforces parties’ agreement.
Arbitration clause – choice of law and forum (English law; LCIA, London); enforcement of arbitration agreement by preliminary objection (Mukisa principle); Arbitration Act CAP 15 (R.E.2020) s.14 referral to arbitration; remedy for breach of arbitration agreement is enforcement/specific performance; referral disposes of domestic proceedings (distinct from stay under s.15).
13 September 2024
Electronic filing rules determine filing time; omission to sign or verify a defence is curable under the overriding objective.
Civil procedure – Preliminary objections – Time-bar – Electronic Filing Rules (GN No.148 of 2018) Rule 21 governs date/time of filing – electronic control number as evidence of filing time. Civil procedure – Preliminary objections – Mukisa principle: POs must be pure points of law free of factual disputes; disputes over service/filing timing require evidence, not PO. Pleadings – Order VI r.14 & r.15 CPC – omission of advocate's signature and verification are procedural irregularities not going to jurisdiction. Overriding objective / oxygen principle – procedural defects in pleadings are curable by amendment rather than striking out where no prejudice or jurisdictional defect exists.
13 September 2024
Court overruled jurisdictional and premature-execution objections, holding execution of a consent decree may proceed and factual disputes require evidence.
Civil procedure – Execution of decree – Execution of consent decree recorded in Deed of Settlement – Jurisdiction of court to execute its own decree (Order XXI, Rule 9). Civil procedure – Preliminary objection – Point of law must be based on ascertained facts; factual disputes (partial satisfaction, breach) are inappropriate for preliminary objection. Consent decrees – Setting aside consent decree requires separate proceedings and is not a prerequisite to execution except where decree validity is challenged on grounds like fraud or mistake.
13 September 2024