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.

57 judgments
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57 judgments
Citation
Judgment date
November 2022
The applicant's revision was dismissed as overtaken by events after execution and sale of the mortgaged property.
Land law – Revisional jurisdiction under s.43(1)(b) Land Disputes Courts Act – application overtaken by events after execution and sale – res judicata/preliminary objection – abuse of court process – uselessness of revision once decree executed.
30 November 2022
Whether dismissal for alleged misappropriation was substantively and procedurally fair, including admissibility of debt-collector evidence.
Labour law — admissibility of debt-collector evidence — hearsay; framing of issues and suo motu subsidiary questions by arbitrator; procedural and substantive fairness in dismissal for misconduct; constitution of disciplinary committee (sufficient seniority, impartiality).
30 November 2022
Out-of-court settlement and non-apparent alleged illegality do not justify extension of time to appeal.
* Civil procedure — extension of time — applicant must show good cause and account for each day of delay. * Settlement negotiations — out-of-court settlement attempts do not stop limitation periods. * Illegality — only apparent, facial illegality justifies extension of time; non-apparent errors require full appeal process.
29 November 2022
Application to restore execution struck out for failure to disclose necessary award history and follow required procedure.
Execution proceedings – restoration/re-enrolment – procedural compliance with deputy registrar’s directions – sufficiency of record regarding award and intervening history – Labour Court Rules (Rules 35, 36, 55) and Limitation Act considerations.
28 November 2022
Negligence of an advocate does not justify extension of time unless applicant accounts for delay; application dismissed.
* Extension of time – application for revision of CMA award – requirement to show good cause. * Negligence of advocate – absence of affidavit and right to be heard; negligence generally binds the client. * Illegality – must be apparent on the face of the record to justify extension of time. * Duty of litigant to follow up progress of case; option to refile where matter struck out.
28 November 2022
Court set aside CMA computation for lacking proper reference to the original award and ordered High Court to compute.
* Labour law – computation of CMA award – identity and reference to originating award – fatal irregularity where computation bears different registration number and does not reference original award. * Civil procedure – execution – jurisdiction of executing court under Section 38(1) CPC to compute decree. * Limitation – Rule 30 GN No.64 (correction/computation) – applicant must prove date of awareness for time computation.
28 November 2022
Failure to administer oath to a recalled witness vitiated arbitration proceedings; award quashed and retrial ordered.
* Labour law — arbitration procedure — recall of witness under section 147(4) Evidence Act — limits on recalling to prevent filling gaps in evidence. * Evidence — requirement of oath/affirmation — mandatory under Oaths and Statutory Declarations Act s.4(a) and Rule 25(1) GN. No. 67/2007 — failure vitiates proceedings. * Remedies — where evidence partly sworn and partly unsworn and arbitrator relied on both, award must be quashed and trial held de novo before different arbitrator. * Practice — arbitral records must avoid ambiguous abbreviations and jargon to prevent prejudice.
28 November 2022
28 November 2022
Employer failed to prove fair termination; award reduced to salaries for remaining six months and 16 days (TZS 2,378,000.33).
Labour law – unfair termination – employer’s burden under s.39 ELRA to prove fairness; procedural compliance with filing/tendering documentary evidence in CMA proceedings; correction of clerical errors in party names under Rules; assessment of contract duration and compensation for premature breach of fixed-term contract.
25 November 2022
24 November 2022
Deputy Registrar lacked jurisdiction to order recalculation; execution must proceed and a name change does not defeat the decree.
* Execution law – executing officer’s jurisdiction; functus officio; power to order recalculation; executing court’s exclusive jurisdiction to determine execution-related quantum; change of decree debtor’s name does not defeat enforcement.
24 November 2022
Court granted 14‑day extension to file revision due to arguable jurisdictional issues including diplomatic immunity and public service status.
Labour law – extension of time to file revision; apparent illegality on face of record; jurisdictional challenge based on Diplomatic Immunities and Privileges Act; jurisdictional challenge based on Public Service Act; Lyamuya exception for extension of time.
22 November 2022
Unsupported advocate illness and failure to account for each day of delay justify refusal to extend time to appeal.
Labour law – extension of time to file appeal – requirement to account for each day of delay; reliance on advocate’s illness – need for medical evidence/affidavit; ignorance of law or afterthoughts not good cause; authorities including Bushiri v. Mashayo applied.
22 November 2022
Voluntary Agreement was operative and the respondent unfairly retired the complainant, who is awarded TZS 176,476,186 for unpaid benefits and losses.
Employment law – medical retirement – requirement for Medical Board certification and fair procedures; Collective/Voluntary Agreement – duration and enforceability; entitlement to retirement award, insurance benefits and compensation for loss of earnings; employer’s duty to accommodate disability.
21 November 2022
An express contractual clause excluding renewal extinguishes reasonable expectation; CMA award for unfair termination quashed.
Labour law — fixed-term contracts — interpretation of contract clauses — Clause excluding legitimate expectation of renewal — timeliness of referral (counting from contract expiry) — scope of CMA jurisdiction to treat non-renewal as unfair termination.
21 November 2022
Fixed-term contract termination was substantively and procedurally unfair; employer failed to prove specific misconduct and omitted required procedures.
Employment law – unfair termination – fixed-term contract – substantive fairness: necessity of proving specific misconduct; procedural fairness – requirement to notify charges, serve investigation report, and afford opportunity to mitigate (Rule 13(2) & 13(7) GN. No. 42 of 2007) – remedy: compensation for unexpired fixed-term period.
18 November 2022
Failure to record assignment or reasons for reassignment of arbitrator vitiates CMA award and mandates retrial.
Arbitration procedure – Assignment of arbitrators – Successor arbitrator must be formally assigned and record reasons for taking over; failure to do so and failure to record witness testimony vitiates CMA proceedings and renders award a nullity.
18 November 2022
Medical illness (COVID‑19) with credible proof can constitute good cause for extension to file a revision.
Labour law — extension of time to file revision — Rule 56(1) & (3) — good cause — medical illness (COVID‑19), hospitalization and isolation — service and Rule 24(4) counter‑affidavit — ex parte proceedings.
17 November 2022
Applicant (fixed‑term) dismissed for misconduct; substantive cause found but disciplinary procedures breached—three months’ pay awarded.
* Employment law – fixed‑term contract – construction of written agreement establishing one‑year term. * Employment law – unfair dismissal – substantive fairness (dishonesty/fuel receipts) established by documentary evidence. * Employment law – procedural fairness – requirement for pre‑disciplinary investigation under GN No. 42 of 2007; failure to investigate vitiates dismissal. * Remedy – where substantive cause exists but procedures breached, award of limited compensation (three months’ pay) rather than reinstatement.
16 November 2022
Suo motu determination of jurisdiction by an arbitrator without hearing parties violated natural justice; award quashed and remitted.
* Labour law – Jurisdiction – Fixed-term contract v. unfair termination – Appropriate remedy and forum. * Natural justice – Right to be heard – Arbitrator raising and deciding issues suo motu without putting them on record. * Procedural fairness – CMA award quashed and remitted for recomposition and hearing on jurisdiction if necessary.
16 November 2022
Conviction may justify dismissal, but employer must show connection to loss and follow fair disciplinary procedures.
Employment law – dismissal for gross misconduct – plea-bargain conviction as basis for termination – necessity of connection between criminal conduct and employer's loss – obligation to conduct and disclose employer investigation (audit) – service of disciplinary notice and Rule 13(3) (48 hours) – procedural fairness.
16 November 2022
Appellant failed to prove lawful village allocation; letters alone were insufficient and the appeal was dismissed with costs.
* Evidence — burden and standard in civil cases — party alleging village land allocation must prove allocation on balance of probabilities (Evidence Act ss.110-112). * Village Land — proof of allocation — need for Village Assembly/Council records or testimony; VEO letters alone insufficient. * Civil procedure — failure to call material witnesses — adverse effect on claimant’s case. * Clerical errors — discrepancy in judgment figures curable where typographical and not affecting outcome.
16 November 2022
Court summoned respondent's directors to show cause for committal after respondent stalled execution of a CMA award.
Enforcement of CMA award; execution of judgments; committal proceedings under Rule 35(1) CPC; effect of unserved set-aside application at CMA on execution; parties' duty to serve and disclose pending applications.
16 November 2022
Termination by mutual agreement upheld; employee bound by signed separation agreement and entitled only to agreed statutory benefits.
Labour law — Termination by agreement; revisional jurisdiction; issues not raised before CMA cannot be entertained on revision; signing of documents — literate adult bound by signed agreement; entitlement limited to agreed statutory/separation‑agreement benefits.
16 November 2022
Termination compensation is taxable; P.A.Y.E must be deducted from awards and remitted to TRA, employer may not retain it.
* Employment law – termination compensation – award for unexpired fixed-term contract – taxability under Income Tax Act s.7. * Income tax – P.A.Y.E – deductions from termination awards and remittance to TRA. * Employer retention of deducted statutory amounts – rejected. * NSSF deductions raised but not permitted to be retained by employer.
16 November 2022
The applicant’s attempted rape conviction quashed for defective particulars and failure to prove the victim’s age.
Criminal law — Attempted rape — Particulars of offence must disclose essential ingredients (manifestation by threat under s.132(1)(2)(a)) — Proof of complainant’s age essential in sexual offences — Defective particulars and unproven age vitiate conviction.
15 November 2022
A 15‑day delay due to retrenchment hardship and lack of funds justified condonation; the CMA ruling was set aside.
Labour law – condonation for late filing – application of Lyamuya principles (inordinate delay, diligence, negligence, other sufficient reasons) – retrenchment hardship and lack of funds as good cause – review of CMA discretionary decision.
15 November 2022
Court finds termination unfair/constructive, quashes CMA award and orders TZS 11,530,769.23 in compensation with each party to bear own costs.
Labour law – constructive dismissal – employer’s duty to prove fairness of termination (s.39 Employment and Labour Relations Act) – procedural and substantive fairness (s.37) – compliance orders and employer conduct – revision of CMA award.
15 November 2022
The respondent’s signed acceptance of a retrenchment package estops them from claiming unfair termination compensation.
• Evidence — Electronic evidence — Admissibility governed by reliability, integrity, origin and authenticity; no mandatory affidavit requirement under Electronic Transactions Act or Evidence Act. • Labour law — Retrenchment — Effect of signing redundancy notice and accepting retrenchment package — issue estoppel bars subsequent claim of unfair termination. • Civil procedure — Review of arbitral/administrative award where estoppel and evidential findings negate primary relief.
15 November 2022
Applicant’s claim of unfair dismissal dismissed—court found he absconded and denied himself a disciplinary hearing.
Employment law — unfair termination — whether employee was terminated or absconded; procedural fairness — right to be heard; evaluation of evidence by arbitrator; review of CMA award.
11 November 2022
Interpretation application dismissed as sub judice and execution struck out for abuse of court process.
* Labour law – enforcement of CMA award – revision of CMA award by High Court – execution of decree versus execution of original CMA award. * Civil procedure – interpretation of judgment – sub judice doctrine – abuse of court process – striking out execution application. * Remedies – proper recourse against High Court judgment is appeal to Court of Appeal.
11 November 2022
Court pierced corporate veil to hold directors liable and allow execution of an unpaid CMA settlement.
Company law — lifting corporate veil; Enforcement of labour/CMA settlement as a decree; Directors' liability where settlement signed with their consent; Insufficiency of company assets not automatically fatal to execution; Authority and apparent consent of company representative; Public interest in enforcement of court decrees.
11 November 2022
Failure to obtain the mandatory medical report and consultation rendered a sickness-based termination procedurally unfair despite substantive justification.
Employment law – termination for sickness – substantive fairness vs. procedural fairness – mandatory medical report and consultation under Collective Bargaining Agreement (Clause 9.1) and Rule 7(1) G.N. No. 42 of 2007 – revisional jurisdiction – remedy: compensation of months' pay for procedural unfairness.
11 November 2022
The Registrar found the respondent embezzled members' funds; failure to meet accounting obligations warranted cancellation.
Trade union registration — cancellation under s55 ELRA — Registrar's investigatory power under s52(2)(b) — obligation to keep books and prepare financial statements under s51(1) — special audit admissibility — embezzlement/misapplication of members' funds — remedial order vs cancellation.
11 November 2022
Defective signing of the CMA referral rendered the proceedings incompetent and the award was quashed.
Labour law – Competence of CMA referral – Proper signing of CMA F1 and consent to representative filing – Defective/forged signatures render referral incompetent – Competence defects make proceedings nullity and award liable to be quashed and set aside.
10 November 2022
A letter labelled 'suspension' that effects dismissal without a disciplinary hearing constitutes unfair termination for lack of fair procedure.
Employment law — suspension versus termination; procedural fairness — right to be heard and disciplinary hearing; Rule 13 Employment and Labour Relations (Code of Good Practice) Rules GN. No. 42 of 2007; unfair dismissal — substantive and procedural irregularities; review of CMA awards.
10 November 2022
Retrenchment for reduced funding and office relocation was substantively and procedurally fair; overtime claims unproven and time-barred.
Labour law - retrenchment for operational requirements; proof of economic necessity and relocation; procedural compliance for retrenchment (notice and consultation); estoppel/promissory estoppel after acceptance of retrenchment package; overtime/extra duty claims - burden of proof and time limitation/condonation.
9 November 2022
Withdrawal with leave permits refiling the same cause of action; different claims require fresh filing and condonation if late.
Labour law – withdrawal with leave to refile – leave to refile limited to same cause of action; jurisdictional limits where different cause of action and differing limitation periods (Rule 10(1)&(2) GN No.64/2007); condonation required for out‑of‑time fresh claims.
9 November 2022
Employee dismissed for negligently facilitating a fictitious account; dismissal and procedures upheld, appeal dismissed.
Labour law – fair termination – employer must prove substantive reason for dismissal; burden of proof lies on employer; suspension during investigation not mandatory; right to be heard and procedural fairness assessed by tribunal records; negligent facilitation of fictitious account causing quantifiable loss justified dismissal.
9 November 2022
Failure to administer oath to CMA witnesses vitiated proceedings, so the award was quashed and rehearing ordered.
Labour law – Evidence – Mandatory administration of oath/affirmation to CMA witnesses; failure to swear witnesses vitiates proceedings and award; remedy: quashing award and ordering rehearing de novo before different arbitrator.
9 November 2022
Revision of interlocutory CMA order struck out as premature under Rule 50 for lack of jurisdiction.
* Labour law – Revision jurisdiction – Whether High Court may revise interlocutory/condonation orders of the CMA while the substantive matter is pending – Application of Rule 50, Labour Court Rules (G.N. No. 106 of 2007) – Striking out premature revision applications.
9 November 2022
Termination was substantively justified but procedurally flawed; court awarded six months' salary as compensation.
Employment law – unfair dismissal – substantive fairness (gross insubordination) upheld; procedural fairness breached – chairperson’s status not disclosed; absence of recorded witness evidence – procedural irregularity; remedy: reduced compensation (six months' salary) for procedural unfairness.
9 November 2022
Applicant failed to account for three-year delay; alleged illegality was not apparent, so extension of time was refused.
Extension of time – application to file notice of appeal and obtain record; requirement to account for each day of delay; illegality as ground for extension – must be apparent on the face of the record; technical delay not established by unrelated subsequent proceedings; afterthought does not justify extension.
8 November 2022
Whether the respondent was an employee and entitled to remedies for unfair termination — court found employment and reduced award.
Labour law – employment status – determination of employee under section 61; unfair termination – substantive and procedural fairness; evidentiary weight of identity cards, attendance registers and payment vouchers; general damages require claim and evidential justification; correct computation of severance pay.
8 November 2022
The appellant failed to prove lawful village allocation; respondent's long possession established ownership and appeal dismissed.
* Land law – village land allocation – requirements under Village Land Act s.8(5) – need for documentary proof (application letters, council/assembly minutes). * Evidence – civil standard (balance of probabilities) – weight of continuous possession and cultivation as proof of ownership. * Precedent/previous proceedings – limited probative value of Ward Tribunal judgments on different parcels or parties. * Procedure – locus in quo visits are discretionary, not mandatory, and only for exceptional necessity.
8 November 2022
Alleged illegality must be apparent on the record to justify extension of time for revision of a CMA award.
Labour law – extension of time to file revision – illegality as sufficient cause – illegality must be apparent on the face of the record – probationary employment – review of CMA award.
7 November 2022
Fixed‑term contract renewed by conduct; termination found substantively and procedurally unfair; compensation limited to remaining contract period.
Employment law – fixed‑term contract vs unspecified period – renewal by conduct; unfair dismissal – substantive and procedural fairness under sections 37 and 39 ELRA; disciplinary consistency – Rule 12 Code of Good Practice; remedies for breach of fixed‑term contract limited to unexpired contract period; CMA jurisdiction where termination occurs before contract end.
7 November 2022
Extension of time refused where applicant failed to account for over five months' delay and show good cause.
Extension of time — good cause required — applicant must account for each day of delay — Lyamuya principles applied — inordinate delay of over five months unjustified by absence from jurisdiction or family responsibilities — Section 91(1) ELRA and Rule 56(1) Labour Court Rules.
7 November 2022
Oral reinstatement after a termination letter postpones the start of the 30‑day limitation until the employer's final decision.
Labour law — limitation period for unfair termination (Rule 10(1) GN No.64/2007) — effect of employer’s oral reinstatement on finality of termination — 30-day period runs from employer’s final decision or operative termination date — CMA award set aside and remitted for merits hearing.
4 November 2022
An employer failing to prove abscondment cannot avoid unfair termination liability; 12 months' compensation upheld.
Employment law – employment relationship – employer’s duty to keep records (s15 ELRA) – burden to prove status and abscondment; termination – proof of termination (oral evidence vs. written letter); unfair termination – compensation under s40 ELRA – 12 months' wages where specific entitlements not pleaded or proved.
4 November 2022