High Court Labour Division

High Court Labour Division is responsible for hearing and determining employment disputes. It was first inaugurated and launched in June 2007 under the Employment and Labour Relations Act.

67 judgments
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67 judgments
Citation
Judgment date
August 2018
Court set aside CMA ex-parte award for failure to consider applicant's good-cause excuses and ordered rehearing.
Labour law – ex-parte awards – setting aside ex-parte order for good cause – right to be heard – judicial exercise of discretion – s.91(4)(b) Employment and Labour Relations Act – adjournment for bereavement and witness unavailability – rehearing before different arbitrator.
24 August 2018
Court set aside CMA's compensation award after finding unlawful reliance on telephonic testimony and procedural unfairness.
Labour law — unfair termination — procedural fairness and right to cross-examination; inadmissible reliance on telephonic testimony absent proper cross-examination; remedy under s.40(1) ELRA — reinstatement v. compensation; natural justice; review of CMA award.
24 August 2018
Termination for negligence and loss held substantively and procedurally fair; CMA compensation award quashed and revision dismissed.
Labour law – wrongful/valid termination – misconduct and negligence causing employer’s financial loss; procedural fairness under Rule 13 (48-hour notice, right to representation); arbitrator’s compensation award review and justification.
17 August 2018
Fixed‑term employee’s dismissal for brief absence was substantively and procedurally unfair; awarded notice, leave, remaining salary and certificate of service.
* Employment law – unfair dismissal – substantive fairness: employer must prove valid reason related to conduct, capacity or operational requirements (s.37(2) ELRA; ILO Convention 158). * Employment law – procedural fairness: requirement to investigate and afford employee a hearing before termination (GN 42/2007 rule 13; ILO Convention 158). * Fixed‑term contracts – remedy for wrongful termination: pay for remaining contract period, notice pay, leave pay, certificate of service. * Jurisdictional limit – High Court Labour Division cannot adjudicate statutory pension (PPF) contribution disputes.
17 August 2018
Court upheld CMA: non‑transparent restructuring that made work intolerable amounted to constructive termination, award affirmed.
Employment law – constructive termination – Rule 7(1) GN.42/2007; restructuring and employer conduct; onus on employee to prove resignation not voluntary; restoration of dismissed CMA file – Rule 29 GN.64/2007; compensation for constructive dismissal.
17 August 2018
Applicant failed to prove an employment relationship; CMA award dismissing the claim is confirmed.
Labour law – employment relationship – application of section 61 LIA and ILO Employment Relationship Recommendation (2006); criteria: control/supervision, integration, economic dependence, exclusivity; absence of written contract examined by surrounding facts; failure to prove employee status warrants dismissal of claim.
17 August 2018
Court holds retrenchment substantively and procedurally fair; applicants' revision dismissed.
Labour law – retrenchment – substantive fairness – operational reasons (loss of contract); Procedural fairness – s.38(1) Employment and Labour Relations Act – consultation and trade union involvement; Evidence – presence of union officials may suffice even without written invitation; Revision – appellate scrutiny of arbitrator’s findings.
17 August 2018
CMA award of compensation for unfair termination upheld due to employer’s failure to observe required fair dismissal procedures despite an unlawful strike.
Labour law — unfair termination — resignation vs. dismissal; Code of Good Practice GN No. 42/2007 — Rule 13 (fairness of procedure) and Rule 14 (strike conduct); burden of proof on voluntariness of resignation; review of CMA award; effect of unlawful strike on procedural fairness requirements.
17 August 2018
An appeal is incompetent where it is brought against a person who was not a party to the original trial proceedings.
* Civil procedure – Competency of appeal – Appeal must be against a party to original proceedings; appeal against non-party is incompetent and renders subsequent proceedings a nullity. * Locus standi – Contract law – Third party not privy to contract has no locus to sue under that contract. * Representation – Power of attorney required to authorise another to institute or conduct suit on behalf of a party. * Evidence – Absence of a material exhibit in the court file undermines reliance on it.
10 August 2018
Appeal allowed: respondent lacked locus standi and trial hearing was procedurally defective; lower judgments quashed.
* Land law – locus standi – a litigant must have a legal interest in the disputed land to sue; * Procedural fairness – right to be heard; trial beginning with cross‑examination noted as irregularity; * Appeal – quashment of proceedings and setting aside of lower tribunals' judgments where locus standi and hearing defects exist.
9 August 2018
May 2018
Unexplained delay and inadequate recording of CMA proceedings vitiated the award; matter remitted for rehearing.
Labour law — Arbitration procedure — Failure to deliver CMA award within 30 days (s.88(9) ELRA) and inadequate recording of proceedings vitiate arbitral award; remedy is quash and remit for rehearing under s.91(4)(b).
25 May 2018
A counter-affidavit signed only in a firm name is defective; the individual advocate must be identified, and leave to amend was granted.
Advocates Act (ss.43–44) – endorsement of drawer’s name – firm/business name insufficient – pleadings must show individual advocate who drew or filed document – defective counter‑affidavit struck out; leave to amend granted under Labour Court Rules.
25 May 2018
Court dismisses employer’s revision and upholds CMA finding of substantively unfair termination due to lack of valid evidence.
Labour law — jurisdiction and timeliness of CMA referrals; right to be heard — issue framing and natural justice; unfair termination — employer’s burden to prove valid reason and adducing admissible evidence; disciplinary sanctions — proportionality and HR manual vs statutory code; remedies — reinstatement or compensation under Employment and Labour Relations Act.
23 May 2018
Applicant failed to show good cause or account for days of delay; extension of time to file review denied.
* Labour procedure – Extension of time – Rule 56(1) Labour Court Rules GN 106/2007 – good cause required. * Delay – applicant must account for each day of delay; unsupported informal follow‑ups insufficient. * Limitation – statutory time limits cannot be waived by parties; diligence is required.
23 May 2018
Where no termination was proved and no disciplinary process occurred, the arbitrator’s finding of unfair termination was quashed.
Employment law – unfair termination – jurisdiction where employee served less than six months – requirement for disciplinary investigation and termination letter – burden of proof on employer (Rule 9(3) GN 42/2007) – procedural fairness under section 37 ELRA and Rule 13 Code of Good Practice.
18 May 2018
Omission to cite s.94(1)(e) ELRA rendered the extension application incompetent and it was struck out with leave to refile.
Labour law — Procedure — Competence of application — Non‑citation of statutory enabling provision (s.94(1)(e) ELRA) — Jurisdictional defect — Incompetent applications to be struck out; leave to refile in interests of justice.
18 May 2018
Applicant’s revision held timely and properly cited but struck out for defective supporting affidavit; leave to refile in seven days.
* Labour law – revision of CMA award – time limit runs from service of the award; applicant must prove date of service. * Civil procedure – affidavit verification – non‑compliance with Order VI r.15(2) CPC renders affidavit deficient and may render application incompetent. * Procedural competence – citation of multiple provisions including proper enabling provisions is not necessarily fatal where enabling provisions are present. * Remedy – defective application struck out but leave to refile may be granted for interest of justice.
18 May 2018
Applicant’s retrenchment for operational requirements was substantively and procedurally fair; revision dismissed.
Labour law – retrenchment/operational requirements – genuineness of operational reason – procedural fairness under s.38(1) ELRA and Rule 23 GN.42/2007 – review of CMA award for pretext and material irregularity.
18 May 2018
Mediator’s dismissal breached applicant’s right to be heard and statutory time limits; matter remitted for fresh CMA mediation.
* Labour law – mediation and arbitration – whether mediator lawfully dismissed a dispute without hearing and whether statutory 30‑day mediation period was breached (s.86(4) ELRA). * Procedural fairness – right to be heard and recusal of mediator. * Civil procedure – non‑compliance with Labour Court Rules (Rule 28) vitiating CMA order. * Remedy – remittal to CMA for fresh mediation before different mediator.
18 May 2018
Whether the arbitrator properly awarded limited remedies for unfair termination of a fixed‑term contract.
Labour law – unfair termination – remedies available to arbitrator – CMA may grant remedies not pleaded but must be supported by evidence; fixed‑term contract – severance pay requirement of 12 months' continuous service; entitlement to transport/subsistence depends on proven place of recruitment.
18 May 2018
Termination found substantively and procedurally unfair; court ordered reinstatement and reduced general damages to TShs. 30,000,000.
* Employment law – unfair termination – substantive and procedural fairness; employer must prove valid reason connected to conduct and follow fair procedure (G.N.42/2007 Rule 13). * Remedy – Section 40 E&LR Act: reinstatement, re‑engagement or compensation; employer’s option if not to reinstate. * Damages – distinction between specific (requires proof/quantification) and general/nominal damages (solatium); court may reduce or substitute CMA awards. * Labour Court revision powers – Section 91 and Rule 28 to vary CMA awards.
18 May 2018
Application struck out for non-compliant affidavit under Rule 24(3); leave granted to file competent application within seven days.
* Labour Court procedure – Rule 24(3) GN No.106/2007 – affidavit requirements: names/description/address of parties; chronological material facts; legal issues arising from facts. * Competence of application – defective affidavit renders application incompetent and liable to be struck out. * Affidavit as sworn evidence – cannot be amended to cure foundational defects. * Res judicata – raised as preliminary objection but not determined where competence disposes of the matter.
11 May 2018
Failure to endorse drawer’s name/address under Advocates Act s.44(1) renders revision application incompetent and struck out.
Advocates Act — section 44(1) endorsement requirement — instruments prepared by non-advocates — section 43 limited to specified instruments prepared for gain — mandatory procedural compliance — Article 107A(2)(e) not a basis to waive statutory procedure — incompetence and striking out.
11 May 2018
A counter‑affidavit lacking the drawer’s endorsed name under s.44(1) Advocates Act is defective and struck out, with limited leave to refile.
Advocates Act s.44(1) – endorsement of drawer’s name and address; Office of the Attorney General (Discharge of Duties) Act s.5(3) – identification of officers acting for AG; competence of pleadings – requirement for individual advocate’s endorsement; striking out defective affidavits; Rule 55(1)-(2) Labour Court Rules – leave to file documents out of time.
10 May 2018
Applicant’s refusal to accept salary pending a pay-rise was not termination; CMA award upheld and revision dismissed.
* Employment law – termination – statutory definition under Section 36 – when conduct constitutes termination versus voluntary resignation/abandonment. * Labour procedure – dispute of interest (claim for salary increase) distinguished from unfair termination. * Judicial review – scope of revision of CMA awards – arbitrator’s recording and assessment of evidence not disturbed absent material error or misconduct. * Evidence – contradictions in dates do not automatically vitiate an award absent proof of prejudice or material misdirection.
10 May 2018
Undue delay and undated correction of a CMA award rendered it improperly procured; award quashed and matter remitted for rehearing.
Labour law – Arbitration awards – Statutory 30‑day time limit for issuing awards (s.88(9)) – Failure to comply renders award improperly procured; Correction/back‑dating of award – Rule 30 / s.90 – undated corrections improper; Jurisdiction – requirement to refer arbitration after failed mediation (s.86(7)); Remedy – revision under s.91(2)(b) and remittal for fresh arbitration.
10 May 2018
Re‑engagement was quashed and three months' compensation awarded where procedural unfairness occurred amid employer restructuring.
Labour law – unfair termination – remedy: re‑engagement versus compensation – effect of employer restructuring and business decline on appropriate remedy; Section 40(1)(a)-(c) Employment and Labour Relations Act; Rule 32(5) GN 67/2007.
8 May 2018
The respondent's counter-affidavit and preliminary objection were struck out for non-compliance with the Advocates Act; leave to refile granted.
Advocates Act s.44(1) – endorsement/name of drawer – procedural competency of pleadings; pleadings filed by unnamed entity defective; court may strike out defective counter-affidavit and notice of preliminary objection; leave to refile; jurisdictional importance of proper endorsement.
7 May 2018
Failure to cite Rule 24(11)(b) renders an extension application incompetent; court struck it out with leave to refile within seven days.
* Labour procedure – applications for extension of time – fall under Rule 24(11)(b) where not specifically provided for. * Civil procedure – non-citation of enabling rule renders application incompetent. * Remedy – strike out and grant leave to refile (first defective application). * Res judicata issue not determined where dispositive preliminary objection disposed of the application.
4 May 2018
Applicants seeking leave to represent multiple employees must prove mandate and existence of those employees before leave is granted.
* Labour procedure – Representative suits – Leave to represent numerous persons – Requirement to prove existence and mandate of those represented – Rule 44(2) Labour Court Rules. * Evidence – Authorization – Unsigned list and affidavit insufficient to establish consent to representation. * Case law – Importance of leave and proof of mandate (citing Hamis Kaka and K J Motors authorities).
4 May 2018
April 2018
Applicant’s illness and travel evidence did not constitute sufficient cause to justify a 25‑month filing delay.
Labour law — Condonation/extension of time — Sufficient cause — Applicant must account for delay (day‑by‑day) — Medical evidence and travel tickets must credibly substantiate incapacity — Dilatory conduct precludes condonation.
27 April 2018
Applicant failed to prove constructive dismissal; CMA award for half‑month salary upheld.
Labour law – constructive termination – Rule 7 GN.42/2007 – burden on employee to prove resignation was involuntary – suspension on full pay and notice to attend disciplinary hearing do not establish intolerable working conditions – CMA award upheld.
27 April 2018
Termination was substantively and procedurally unfair; employer ordered to reinstate applicant with full back pay.
Labour law – unfair dismissal; requirement to investigate before disciplinary hearing (Rule 13 GN No.42/2007); employer must prove clear, known rule breached (Rule 12); impartiality of disciplinary chair – charging person must not chair; mandatory opportunity to mitigate (Rule 13(7)); remedy – reinstatement under s.40(1)(a).
27 April 2018
Whether notice pay is payable where employees were consulted, worked the notice period and received terminal benefits.
* Labour law – retrenchment – procedural fairness – compliance with s.38(1) ELRA and Code of Good Practice; entitlement to notice pay under s.44(1) ELRA. * Notice pay – distinction between payment in lieu of notice and payment where employees worked notice; effect of terminal benefits on entitlement to notice pay. * Review of CMA award – arbitrator’s misapplication of law where procedural compliance and payment of terminal benefits were established.
27 April 2018
Reinstatement upheld where dismissal lacked evidential basis and procedural fairness; employer may opt to pay statutory compensation.
Employment law – unfair termination – substantive fairness and proof of misconduct; Procedural fairness – requirement that notice to show cause correspond to termination grounds and afford right to be heard; Remedies – reinstatement discretionary under s.40(1) ELRA and Rule 32 GN 67/2007; employer’s option under s.40(3) ELRA to pay twelve months’ wages if not reinstating.
20 April 2018
Court upheld unfair dismissals, reduced CMA compensation from 24 to 12 months, and ordered clerical name corrections.
Labour law – unfair dismissal – substantive and procedural fairness; employer’s burden to prove valid reasons and investigation; discretionary compensation under s.40(1)(c) limited by fairness; arbitral award precision and execution; clerical correction of awards under s.90 and Rule 30(1).
20 April 2018
The Court dismissed the applicant's request to call CMA records and to nullify or restrain sale proceeds for lack of merit.
* Civil procedure – Revisionary and supervisory jurisdiction – Whether High Court should call for CMA record for review/revision of arbitral/mediation proceedings.* Interim relief – Application to nullify sale and restrain distribution of proceeds pending determination – Court refused interim preventative orders for lack of merit.* Costs – Applicant sought costs to follow main event.
20 April 2018
Revision dismissed: applicant failed to account for each day of delay and did not plead alleged illegality before the CMA.
Labour law – Extension of time/condonation – Requirements under GN No.64/2007 (Rule 11(3), Rule 29(4), Rule 31); need to account for degree and each day of lateness; alleged illegality must be pleaded to justify extension; afterthoughts inadmissible; mediator’s discretion upheld.
20 April 2018
Applicant's repeatedly defective revision applications (missing verifier/citations) amounted to incompetence and were dismissed with costs.
Labour procedure – Revision application – Defective affidavit (missing verifier name/signature) – Non‑citation of enabling provisions (Sections 91 & 94(1)(b) ELRA) – Repeated non‑compliance with court directions – Dismissal with costs under Labour Court Rules.
19 April 2018
Revision held timely but struck out for fatal affidavit and formal defects; leave granted to refile within 30 days.
Labour law — revision of CMA awards — time limits under Section 91(1)(a)&(b) ELRA; procedural formalities — Advocates Act s.44(1) (drawer endorsement), Civil Procedure Code Order VI r.15(3) (signed verification), Oaths and Statutory Declarations Act ss.5 & 10 and Schedule (jurat format); consequence of mandatory defects — affidavit struck out; leave to refile; Court taking judicial notice of its earlier rulings under Evidence Act s.59(1)(a).
18 April 2018
Fixed-term contracts expire automatically unless a clear, proved representation creates reasonable expectation of renewal.
* Employment law – Fixed-term contracts – automatic termination on expiry absent contractual provision or clear representation – reasonable expectation of renewal required for unfair termination claims (s.36(a)(iii) ELRA; Rule 4 GN 42/2007). * Evidence – burden to prove employer's representations; previous renewals not determinative.
18 April 2018
Attachment set aside because CMA award misnamed the employer and required correction before execution.
* Labour law – execution of CMA awards – attachment of property – misnaming of employer in arbitral award – correction of clerical mistakes under section 90 ELRA and Rule 30(1) GN No.64/2007 – wrongful execution against non-decree debtor; relief: lifting of attachment and release of vehicles.
18 April 2018
An application to extend time to file a notice of appeal is incompetent if Section 11(1) AJA is not invoked.
Labour Court – Extension of time – Notice of appeal – Jurisdiction – Appellate Jurisdiction Act section 11(1) must be invoked where extension concerns Court of Appeal time limits; Rule 56 Labour Court Rules cannot be used in isolation – incompetence for failure to cite section 11(1); jurisdiction may be raised suo motu; advocate’s negligence not automatically sufficient cause.
17 April 2018
Termination was substantively justified for absenteeism but procedurally unfair for denying a proper disciplinary hearing, meriting 12 months' compensation.
Labour law — termination for absenteeism — substantive validity of reason for dismissal; procedural fairness — right to be heard — burden on employer to prove fair procedure under GN 42/2007 and ELRA; remedies — compensation under s.40(1)(c).
13 April 2018
A revision application supported by an affidavit lacking mandatory contents and a proper jurat is incurably defective and struck out.
* Labour law — Revision of CMA award — procedural competence of revision applications. * Civil procedure — Affidavit contents — Rule 24(3) Labour Court Rules — requirement for statement of legal issues. * Oaths and Statutory Declarations Act (Cap.34) — jurat identification — Section 10 — material requirement. * Incurable procedural defects — striking out incompetent applications.
13 April 2018
A revision of a CMA award was dismissed as time-barred under ELRA section 91(1).
Labour law – Revision of CMA awards – Time limitation for filing revision under ELRA s.91(1) – Labour Court’s revisionary jurisdiction under s.94 and Rule 28 – Effect of settlement/quantification dates on limitation period.
13 April 2018
Applicant failed to show good cause for extension; counsel’s negligence and failure to attach the impugned order were decisive.
Labour procedure – extension of time to apply to set aside dismissal orders – requirement to show good cause; negligence of counsel not sufficient ground; applicant must account for delay and attach impugned order.
6 April 2018
Court finds dismissal substantively and procedurally unfair, requires minimum 12 months' compensation and revises terminal awards.
Employment law — unfair dismissal — substantive and procedural fairness; remedy — statutory minimum twelve months' compensation; awards without pleadings or evidence; repatriation and subsistence entitlements; time-barred terminal benefits.
6 April 2018
Extension application struck out for defective affidavit/endorsement, but applicants granted 14 days to refile a competent application.
* Labour procedure – extension of time – requirement to account for delay – sufficient cause. * Procedural competence – supporting affidavit must be drawn and endorsed by an individual advocate; firm name alone is insufficient (Advocates Act s.44(1)). * Incompetence and striking out – defective affidavit struck out; application declared incompetent under Labour Court Rules. * Court power – jurisdictional/procedural competence may be raised suo motu; leave to refile granted to cure defects.
6 April 2018
Affidavit failing to state legal issues and reliefs under Rule 24(3) renders revision application incompetent and struck out.
Labour Court Rules — Rule 24(3)(c) & (d) — Affidavit must state legal issues arising from material facts and reliefs sought — Defective affidavit renders revision application incompetent — Proper preliminary objection — Leave to refile.
6 April 2018