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.

82 judgments
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82 judgments
Citation
Judgment date
April 2022
A defendant’s written admission supports judgment on admission for the admitted debt; installment relief denied for procedural non-compliance.
Civil Procedure – Order XII r.4 (judgment on admission) – Written admission in defence — Commercial Division Rules r.25 (time to pay) — procedural compliance required for installment relief.
30 April 2022
A termination-based dispute was time-barred and improperly routed; statutory time limits and scheme arbitration procedures must be followed.
Labour law — time limits for unfair dismissal/retrenchment claims; applicability of repealed law (Employment Security Act) and extension notice; jurisdiction of CMA; mandatory dispute-resolution routes in trust deeds (arbitration); effect of prior struck-out or decided proceedings on subsequent referrals.
29 April 2022
A later alleged termination is a distinct cause of action; CMA had jurisdiction and remitted the matter for fresh hearing.
* Labour law – jurisdiction of CMA – res judicata – Section 9 Civil Procedure Code – distinct causes of action (1998 termination v. 2013 alleged termination). * Revision – setting aside CMA ruling and remitting matter for fresh hearing. * Application of Paniellotta v Tanaki criteria for res judicata.
29 April 2022
Unpaid salaries established breach of contract; severance awards require proof of 12 months' service and were largely set aside.
Employment law – breach of contract versus unfair termination; unpaid salaries as breach; entitlement to notice and leave; severance under s.42 ELRA requires proof of 12 months' continuous service; parties bound by pleadings (CMAF1).
29 April 2022
Applicant failed to prove respondent’s capacity to be sued; CMA proceedings and award quashed as incompetent.
Labour law – locus standi – capacity to be sued – burden of proof on applicant to establish respondent’s legal personality – proceedings and arbitration award founded on incompetent proceedings are nullity and liable to be quashed.
29 April 2022
Extension of time to seek interpretation denied for failure to plead illegality or show sufficient cause within limitation period.
Labour procedure – interpretation of judgments – limitation period where none provided in rules – Part III item 21 Law of Limitation (60 days); extension of time – requirements: sufficient cause, accounting for days, non-inordinate delay; illegality ground must be pleaded and is for Court of Appeal to correct; out-of-court negotiations do not suspend limitation.
29 April 2022
Revision dismissed: applicant failed to account for each day of delay and showed gross negligence, negating condonation.
Labour law – condonation/extension of time – duty to account for each day of delay; technical delay does not absolve accounting requirement; degree of lateness and negligence; consideration of prospects of success in condonation applications.
29 April 2022
Extension to revise a CMA condonation order dismissed as an impermissible challenge to an interlocutory decision.
Labour law – interlocutory orders – condonation for late filing is interlocutory; Rule 50 Labour Court Rules bars revision of interlocutory decisions unless final; "nature of the order" test to determine finality and jurisdiction.
28 April 2022
Employees of a statutory, government‑owned corporation are public servants; failure to exhaust Public Service Act remedies meant CMA lacked jurisdiction.
Labour law; jurisdiction of CMA over employees of statutory bodies; definition of public servant under Public Service Act; interpretation of Ports Act s.38A and Public Corporation Act; requirement to exhaust Public Service Act remedies before CMA.
28 April 2022
Termination notice valid despite misnomer; final payment settled employment, CMA award affirmed and revision dismissed.
Employment law – termination notice – service and misnomer – validity of termination notice despite incorrect name – payment in lieu/final payment – signature as acceptance – termination date established – CMA award affirmed.
28 April 2022
CMA lacks jurisdiction over disciplinary disputes involving public servants who have not exhausted Public Service Act remedies.
* Labour law — jurisdiction of CMA — disciplinary disputes involving public servants * Public Service Act (s31, s32A) — status of employees of public corporations as public servants * Requirement to exhaust internal remedies under Public Service Act before invoking labour institutions * Exclusive domain of the Public Service Commission — Court of Appeal precedent (Dominic A. Kaiangi)
28 April 2022
A defective verification clause in an affidavit can render an application incompetent and nullify related CMA proceedings.
Labour law — procedure at CMA — service of summons and ex parte proceedings; Civil procedure — competence of affidavits — verification clause essential; defective verification may vitiate proceedings and render applications incompetent.
28 April 2022
An unfair termination referral filed outside the 30‑day limit deprived the CMA of jurisdiction; awards were quashed.
Labour law — Time limits for unfair termination referrals — Rule 10(1) GN. No. 64 of 2007 — Jurisdictional effect of late referral; Ex parte awards — setting aside/execution; Procedural issues — service and capacity to be sued (not determined).
28 April 2022
CMA lacked jurisdiction as the respondent was a public servant employed on unspecified (permanent) terms.
Labour law — Jurisdiction — CMA jurisdiction over employment disputes involving public servants — Unspecified-term employment treated as permanent — Public Service Act s32A requires matters by public servants to proceed to the Public Service Commission — Public corporations within scope of public service jurisdiction (see Kalangi precedent).
28 April 2022
CMA lacked jurisdiction because the railway authority is a public institution and its employees are public servants.
Labour jurisdiction — Whether disputes of employees of a statutory railway authority fall within CMA jurisdiction — Public corporation/public servant status determined by statutory establishment, government ownership/control and public functions — Clause permitting consideration of employee proposals does not oust public servant status.
28 April 2022
A Labour Court revision against a CMA condonation ruling is incompetent because the condonation order is interlocutory.
* Labour procedure – Rule 50 Labour Court Rules – prohibition on revision/appeal against interlocutory CMA orders; * Condonation orders – interlocutory in nature as they permit, but do not decide, substantive rights; * Nature of order test – remedies sought and whether rights were conclusively determined; * CMA forms – Form No.1 initiates substantive dispute; Form No.2 for condonation is incidental.
27 April 2022
27 April 2022
Condonation upheld; Director General lacked unfettered power to reduce public allowances; respondent awarded TZS 88,500,000.
Labour law – entitlement to investigation/hardship allowances; condonation for late referral – estoppel where applicant did not oppose at CMA; public funds and regulatory control over allowances – limits on Director General’s discretion; transfer versus demotion and impact on remuneration.
27 April 2022
Applicant failed to prove an employment relationship; CMA finding upheld and application dismissed.
Labour law — existence of employment relationship — burden of proof on claimant; admissibility of documentary evidence; right to be heard; application of section 61 LIA.
27 April 2022
A CMA ruling granting condonation is interlocutory; revision under Rule 50 is therefore incompetent and struck out.
Labour procedure — Rule 50 Labour Court Rules — revision barred in respect of interlocutory orders; condonation orders at CMA are interlocutory; CMA Form No.1 defines dispute; CMA Form No.2 (condonation) is incidental; nature-of-order test confirmed but fails where substantive reliefs remain undetermined.
27 April 2022
A revision challenging a CMA condonation ruling was incompetent as an interlocutory matter barred by Rule 50.
Labour law – Revision – Interlocutory orders – Condonation of time – Rule 50 Labour Court Rules; CMA Form No.1 (referral) vs Form No.2 (condonation) – Nature of order test – Section 91 ELRA applicable to arbitral awards only.
27 April 2022
A Revision is not competent against an interlocutory CMA condonation order; the application was struck out.
* Labour law – interlocutory orders – condonation of time by CMA – whether such order is subject to Revision; * Procedure – Rule 50 Labour Court Rules – no Revision, appeal or review against interlocutory decisions unless they finally determine the dispute; * Abuse of court process – premature Revision struck out.
27 April 2022
25 April 2022
Court set aside CMA award because the respondent failed to prove termination and the arbitrator misdirected himself.
* Labour law – unfair termination – burden of proof where employer denies termination – employee must first prove termination before remedies under Part III Sub‑Part E are available; tribunal jurisdiction. * Civil procedure – review of arbitral award – misdirection and findings based on assumptions or issues not pleaded constitute material irregularity justifying quashing of award. * Employment disputes – retrenchment evidence and necessity of documentary corroboration for termination or instructions to continue work.
25 April 2022
Employer failed to prove redundancy; termination was unfair, discrimination not shown, compensation reduced to unpaid contract period (USD 65,865.60).
Labour law – fixed-term contract – early termination – breach of contract; redundancy/retrenchment – proof and Section 38 ELRA consultation requirements; discrimination and harassment – statutory definition and proof; jurisdiction – CMA Form No.1 and procedural requirements for lodging disputes; quantum of compensation – remedy limited to remaining contractual period.
25 April 2022
Severance pay is capped at ten years; CMA's calculation under section 42(1) ELRA was correct and upheld.
* Labour law – Severance pay – Section 42(1) ELRA – entitlement of seven days' basic wage per completed year – statutory cap of ten years; * Calculation method – daily wage = monthly salary/26, severance per year = daily wage × 7; * Revision – no basis to disturb CMA award where computation complies with statute.
25 April 2022
Court finds dismissal substantively fair but procedurally unfair; reduces compensation and orders Tshs.162,040,236/- plus certificate of service.
Labour law — disciplinary offences by senior HR manager — substantiated misconduct may justify dismissal; procedural fairness — investigator cannot sit on disciplinary panel (nemo judex in causa sua); arbitrator must give reasons for remedial awards; damages in employment cases are exceptional and require clear justification; dual employment upheld where contractually agreed.
25 April 2022
An omnibus chamber summons combining extension of time and revision is incompetent and was struck out.
* Labour procedure – Omnibus applications – When distinct prayers for extension of time and substantive revisions may be combined – tests: nature and origin, reasoning, and timing. * Jurisdiction – Court not seized to hear substantive application until extension of time granted. * Rule 56 Labour Court Rules – extension of time must be separately and properly sought when limitation has lapsed.
25 April 2022
A time-barred unfair termination claim deprived the CMA of jurisdiction; the award was quashed and set aside.
Labour law — limitation periods and jurisdiction — unfair termination disputes must be filed within 30 days (Code of Good Practice) — lack of condonation renders CMA proceedings and award a nullity.
25 April 2022
Probation does not auto-confirm employment; assault during probation can justify termination without improvement period.
Labour law — Probationary employment — No automatic confirmation upon expiry of probation; confirmation requires employer action; Rule 10(8) procedures apply mainly to performance issues. Labour law — Misconduct — Assault on co-employee is serious misconduct justifying termination under Rule 12(3)(e). Labour procedure — CMA mediator’s award — Dismissal upheld where disciplinary process observed.
25 April 2022
22 April 2022
Revision of CMA award dismissed as time-barred for failure to show leave to file out of time.
* Labour law – Revision of CMA award – Limitation period – Section 91(1) ELRA requires filing within six weeks of service of award; absent proof of leave to extend time, application is time-barred.* Civil procedure – Burden to produce court order or adequate explanation when relying on alleged extension of time.* Prior struck-out proceedings do not cure failure to obtain or show leave to file late.
22 April 2022
CMA lacked jurisdiction to hear a time-barred breach of contract claim filed without condonation.
* Labour law – limitation periods – distinction between unfair termination (30 days) and other disputes including breach of contract (60 days) under Rule 10 GN. No. 64/2007. * Administrative jurisdiction – CMA lacks jurisdiction to entertain time-barred disputes filed without condonation (CMA F2 and affidavit under Rule 11). * Procedural law – withdrawal of one cause of action and grant of leave to refile does not operate as condonation for a different, already time-barred cause of action.
22 April 2022
An arguable illegality in a CMA decision can justify extension of time despite inordinate delay.
Labour procedure – extension of time under Rule 56(1) – good cause required; inordinate delay and need to account for days; illegality in tribunal decisions as sufficient ground for extension; death of director/administration of estate does not excuse delay against corporate respondent; referral within CMA is not a substitute for revision or appeal.
22 April 2022
Revision allowed: unfair termination and January 2020 overtime claims timely; December 2019 overtime time-barred; matter remitted to CMA.
Labour law – condonation and time limits – Rule 10 GN 64/2007 – distinction between unfair termination (30 days) and other disputes (60 days) – time-barred claims – remittal to CMA.
22 April 2022
Labour tribunal lacked jurisdiction over disciplinary disputes of public servants; CMA award quashed and employer's revision allowed.
Labour jurisdiction — whether CMA may determine disciplinary disputes involving public servants — Public Service Act and Public Service Commission exclusivity — lack of jurisdiction vitiates arbitral award.
22 April 2022
Applicant failed to prove good cause or credible excuse to restore a dismissal for want of prosecution.
Restoration of dismissed proceedings; requirement to show good cause and credible affidavit particulars (dates, attachment of dismissal ruling, proof of illness); credibility and inconsistency of affidavit; abuse of process where restoration filed after execution order; public officers’ duty to ensure case continuity.
22 April 2022
Fixed-term contracts expire automatically; 28‑day notice under s.41 is inapplicable and awards based on unpleaded unfair termination are quashed.
Employment law — Fixed-term contracts — Automatic expiry — Whether 28‑day notice under s.41 applies; Pleadings — parties bound by their pleadings — Arbitrator cannot decide unpleaded unfair termination/legitimate expectation claim.
22 April 2022
Re‑engagement improperly granted where applicants did not claim it; award varied to monetary terminal benefits.
Labour law – unfair termination – reliefs; jurisdiction to grant unclaimed reliefs – re‑engagement versus monetary compensation; evidence of employment – effect of absence of proof.
22 April 2022
Extension of time refused where four‑year delay was inordinate and alleged illegality was not glaring on the record.
Labour law — extension of time to apply for revision — Rule 56(1) Labour Court Rules; delay must not be inordinate; applicant must account for each day of delay; alleged illegality must be glaring on the face of the record to justify extension (Lyamuya principles).
22 April 2022
Revision against CMA’s grant of condonation dismissed as interlocutory and therefore not revisable under Labour Court Rules.
Labour law – interlocutory orders – condonation/extension of time; Rule 11(1)-(2) GN 64/2007 – requirement to file condonation with late document; Rule 50 Labour Court Rules – prohibition on revision of interlocutory decisions; competence of revision applications.
22 April 2022
Applicant failed to prove constructive dismissal or employer-made intolerable conditions; revision dismissed for lack of merit.
* Employment law – Constructive termination – three cumulative requirements (termination, intolerability, employer causation) and burden of proof. * Evidence – credibility and trial record – afterthought allegations unsupported by tribunal evidence. * Disciplinary procedure – attendance and consequences of non-attendance; salary entitlement where employee absent from work. * Record-keeping – presumption of authenticity of tribunal/court records; challenges to omitted findings require strong justification.
22 April 2022
Failure to file the mandatory notice under Regulation 34(1) renders a revision application incompetent, and such applications are struck out.
* Employment law – Procedural compliance – Requirement to file notice of intention to seek revision (CMA F10) under Regulation 34(1) – Mandatory and jurisdictional. * Civil procedure – Preliminary objections – issues raised but not argued are treated as abandoned and not considered. * Statutory interpretation – Clear statutory language must be enforced despite practical inconvenience.
22 April 2022
Revision dismissed as time-barred; court holds leave to represent does not extend statutory filing period.
Labour law — Revision of CMA awards — Time limitation under section 91(1)(a) ELRA and Rule 56(1) LCR — Leave to represent is not an extension of time — Preliminary objection for time bar upheld.
22 April 2022
Withdrawal without leave to refile bars the applicant from refiling; extension of time refused.
* Labour procedure – application for extension of time to file revision – effect of prior withdrawal without leave to refile. * Civil procedure – withdrawal of suit/application – leave to refile; finality and res judicata. * Discretionary/inherent power – limits where prior withdrawal was without leave to refile. * Right to be heard – cannot override finality of withdrawal absent leave to refile.
22 April 2022
Ex parte CMA award quashed because claims were time-barred and no condonation was proved, depriving CMA of jurisdiction.
Labour law — limitation periods for referral to CMA — Rule 10(1),(2) GN. No. 64/2007; jurisdictional defect where claims filed out of time without condonation; ex parte award tainted by illegality — nullification and setting aside of CMA proceedings.
22 April 2022
Court struck out the appeal after finding the named respondent had been legally disestablished and could not be a party.
* Administrative law – Legal existence of parties – Disestablishment of a statutory entity and its effect on being joined as a party to litigation. * Civil procedure – Parties and amendment – When amendment to remove a non-existent party would amount to disguising a new appeal. * Abuse of process – Joining a disestablished entity as a respondent constitutes procedural irregularity warranting striking out. * Judicial notice – Court may take judicial notice of statutory disestablishment and Gazette notices.
22 April 2022
Employer's prolonged silence and continued payment after a resignation implied rejection, rendering later acceptance an unfair termination.
Employment law – resignation – implicit acceptance and revocation – employer's silence and conduct; Reasonable time for response to notice; Unfair termination – substantive and procedural fairness under section 37(2) Cap. 366 R.E.2019; Remedy – monetary compensation where reinstatement not pleaded.
22 April 2022
Extension of time denied for failure to account for delay and repeated negligence by applicants' counsel.
* Labour procedure – extension of time to file revision – requirement to account for each day of delay; * Pleading requirement – illegality must be pleaded in affidavit to be relied upon; * Advocate's negligence – repeated errors by counsel may amount to lack of diligence and do not ordinarily justify condonation; * Court record corrections – alleged errors must be promptly and convincingly shown.
21 April 2022
CMA had jurisdiction, but proceedings and award set aside due to counsel’s disqualifying conflict of interest, matter remitted for rehearing.
Labour law – jurisdiction of CMA where dispute preceded amendments to Public Service Act; Advocates' professional conduct – conflict of interest of former company secretary representing an ex-employee; abuse of process – vitiation of CMA proceedings and award; remedy – quash and remit for rehearing.
21 April 2022