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.

47 judgments
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47 judgments
Citation
Judgment date
June 2022
Termination for gross dishonesty upheld; late bias claims and non‑production of investigation report insufficient to overturn dismissal.
* Employment law – unfair termination – substantive fairness – gross dishonesty: altering credit application and concealing information can justify dismissal. * Procedural fairness – investigation report: non-production is not per se fatal where investigation was conducted and employee had opportunity to defend. * Civil procedure – revision: allegations of bias or record tampering first raised on revision are afterthoughts and cannot vitiate award.
30 June 2022
Where the arbitration record is irretrievable and uncertified, the court may quash the award and order a retrial before a different arbitrator.
* Labour law – arbitration award – missing/untraceable CMA record – reconstruction of record versus nullification – trial de novo ordered where certified proceedings unavailable and reconstruction impracticable; reconstruction requires participatory process and confirmatory certification (see Madololyo; Schoombe).
30 June 2022
CMA lacked jurisdiction because the parties’ written agreement was a management (contract for services), not an employment contract.
* Labour jurisdiction – Distinction between contract of service (employment) and contract for services (management) – control, integration, payment, exclusivity relevant. * Jurisdiction – CMA limited to employment contracts listed in section 14(1) of ELRA; management contracts fall outside and are for civil courts. * Remedies – Claims arising from non-employment contracts are not arbitrable before CMA.
30 June 2022
Procedural unfairness in termination reduces compensation where substantive reason (abscondence) existed but proper disciplinary process was not followed.
Employment law – unfair termination – substantive vs procedural fairness; abscondence as serious misconduct; requirement for disciplinary hearing; assessment and reduction of compensation for procedural unfairness; revision of CMA award.
30 June 2022
Illness of counsel and short unexplained delay constituted sufficient cause to extend time to file the appeal; extension granted.
* Labour procedure – extension of time – Rule 56(1) Labour Court Rules, 2007 – good cause required for enlargement of time. * Evidence – medical certificate and affidavit as proof of counsels’ incapacity – relevance to explaining delay. * Delay – short unexplained period not necessarily fatal if not excessive; court’s discretion to extend time.
30 June 2022
Court upheld termination for breach of employer SOP and found investigatory procedures and fairness sufficient; revision dismissed.
Employment law — unfair termination — validity of reasons and procedural fairness — breach of employer SOP and personal business at workplace — application of G.N. No. 42 of 2007 (Rules 12 and 13) — investigatory evidence and admission — CCTV evidence not tendered but investigation found sufficient.
30 June 2022
Court granted seven‑day extension to file revision, finding the short delay excusable and not due to negligence.
Labour law – extension of time to file revision – accounting for delay – technical/excusable delay – no requirement to assess prospects of success before granting extension – s.91(1)(a) ELRA (timing of revision).
29 June 2022
Court grants 14‑day extension where delay was technical, not negligent, allowing filing of notice of intention to appeal.
Extension of time – Appellate Jurisdiction Act s.11(1) – sufficient cause – accounting for delay – technical/incompetent appeal vs negligence – Lyamuya; William Shija; illegality/error apparent on record.
29 June 2022
Application challenging both an out-of-time ex parte award and a timely ruling was dismissed as time-barred.
Labour procedure — Rule 24(1)-(3) Labour Court Rules — alignment of reliefs in notice and affidavit; limitation — time bar for applications to set aside ex parte awards; consequences of combining timely and out-of-time challenges.
29 June 2022
Revision dismissed: revisional court will not reopen unraised issues; CMA properly analysed evidence and upheld retrenchment.
* Labour law – retrenchment – procedural and substantive fairness – consultation obligations under section 38 Labour and Employment Relations Act (Cap 366 R.E.2019) – consultation steps are guidelines, not a rigid checklist. * Evidence evaluation – sufficiency of notices, selection method (LIFO) and exhibits in upholding validity of retrenchment. * Revision jurisdiction – revisional court will not entertain new issues not raised at the CMA. * Reliefs – awards must be within prayers sought at CMA.
28 June 2022
Extension of time granted to file revision where alleged illegality (wrong party sued) and counsel’s inaction caused delay.
* Labour — Extension of time — Revision of CMA award — Delay attributed to advocate's failure to prosecute — Execution initiated. * Procedural law — Illegality in impugned decision (wrong party sued) — illegality as good cause for extension (Valambia; VIP Engineering). * Service — substituted service and ex parte prosecution of application (respondent absent).
28 June 2022
Review dismissed: no apparent error and dispute was time-barred; appeal, not review, was the proper remedy.
* Labour law – review of court decisions under Rule 27(7) – requirement for concise grounds without narration or argument. * Civil procedure – review vs appeal – apparent error on the face of the record must be self-evident. * Jurisdiction – CMA time limits for filing disputes and effect of failure to seek condonation.
27 June 2022
Fixed-term contract expired as agreed; absence of employee's renewal notice meant no reasonable expectation and no unfair termination.
* Employment law – Fixed-term contracts – Automatic expiry of fixed-term contracts unless contract provides otherwise – Rule 4(2) GN No.42/2007. * Employment law – Reasonable expectation of renewal – Employee duty to demonstrate employer conduct or representations giving rise to expectation; failure to notify renewal as contractually required defeats claim. * Labour procedure – Revision of CMA award – Court will not interfere where contract terms and evidence show no unfair termination.
27 June 2022
The applicant’s review was an appeal in disguise; no patent error on the face of the record justified review.
Labour law — Review jurisdiction — Error apparent on the face of the record — Appeal in disguise — Review limited to patent mistakes or newly discovered evidence — Re‑evaluation of evidence not permissible under review.
27 June 2022
Employer failed to prove misconduct; dismissal substantively unfair and arbitral compensation upheld under ELRA.
* Employment law – unfair dismissal – substantive and procedural fairness – employer bears onus to prove misconduct. * Evidence – contradictions between employer witnesses and disciplinary record undermine allegations of employee misconduct. * Disciplinary procedure – hearing findings (suspicion vs. guilt) cannot be supplanted by termination letter. * Remedies – arbitrator entitled to compensation under Employment and Labour Relations Act (ss.40(1)(c), 41(5), 42).
27 June 2022
Arbitrator erred by awarding one-month compensation rather than statutory twelve months for unfair termination.
* Labour law – Unfair dismissal – substantive and procedural fairness; statutory compensation under s.40(1)(c) – twelve months' salary. * Revision – review of CMA award – error of law in quantum of compensation. * Evidence – employer's burden to justify operational requirements; unsupported afterthought rejected. * Proof of monetary claims – salary arrears dismissed for want of evidence.
27 June 2022
Condonation dismissed where sickness evidence lacked credibility and applicant failed to account for each day of delay.
Labour law – condonation/extension of time – fixed-term contract non-renewal – requirement to account for each day of delay – credibility of affidavit evidence (traditional healer) – arbitrator’s discretion and consideration of prospects of success under Rule 11(3)(c).
27 June 2022
Application to set aside union election dismissed as time-barred where applicants filed beyond the 60-day limitation.
Labour law — union election disputes — limitation period where none specified in union rules — Rule 55 Labour Court Rules — application of Law of Limitation Act (60 days) — time-bar — mandatory nature of limitation — dismissal of out-of-time applications.
17 June 2022
Serving an end-of-contract notice after automatic renewal and after work commenced rendered the respondent's termination unfair; CMA award upheld.
Employment law – fixed-term contract – automatic renewal – notice served after renewal – procedural and substantive unfair termination; evidential burden to prove salary for compensation calculations; review of CMA award.
17 June 2022
Employer proved fair termination for negligent unauthorised conduct; procedural irregularities immaterial due to admissions; reinstatement inappropriate.
Employment law – unfair termination – burden on employer to prove fair reason and fair procedure (s.39, s.37(2) ELRA); negligence in banking – unauthorised alteration of security; procedural fairness – admissions may render full disciplinary hearing unnecessary; remedy – reinstatement inappropriate where trust destroyed.
17 June 2022
A strike-out for mixed time‑bar claims was interlocutory; revision under Rule 50 was incompetent and dismissed.
Labour law — Procedural law — Revision jurisdiction — Order striking out for time-bar issues held interlocutory and not revisable under Rule 50 of the Labour Court Rules; finality of rights is the test for revisionability.
17 June 2022
Mediator erred dismissing a labour claim as time‑barred where disputed factual evidence on termination was not before the CMA.
* Labour law – preliminary objection – time‑bar – where date of termination/notification is disputed, preliminaries requiring evidence cannot dispose of claim. * Evidence – competence and admissibility – documents not in record cannot be relied upon at preliminary stage. * Procedural fairness – right to be heard and to cross‑examine on evidence tendered. * Civil procedure – remittal to CMA for arbitration on merits where disputed facts exist.
17 June 2022
Court granted extension of time to file revision, finding good cause and that the delay was not inordinate.
* Labour law – extension of time to file revision under section 91(1)(a) – six-week limitation period. * Civil procedure – Rule 56(1) Labour Court Rules – court’s discretionary power to extend time on good cause shown. * Procedural defects/striking out – whether corrective refiling delay constitutes sufficient cause. * Requirement to account for each day of delay and concept of inordinate delay.
16 June 2022
Material discrepancies and unexplained reassignment at the CMA vitiated the proceedings; award quashed and rehearing ordered.
Labour procedure — Arbitration proceedings — Material discrepancies between handwritten and typed records; reassignment of arbitrator without reasons — Proceedings vitiated — Award quashed — Hearing de novo ordered.
15 June 2022
Revision dismissed: absence of evidence of missing work permit meant CMA retained jurisdiction and award confirmed.
Labour law – unfair termination – jurisdiction of CMA – foreign employees and work permits – burden of proving absence of work permit – issues must be pleaded and proved at CMA; revision cannot raise new factual issues.
15 June 2022
Arbitrator lawfully awarded 12 months' compensation; CBA entitlements unpleaded and unproven, revision dismissed.
Labour law – retrenchment – remedies for unfair termination under Section 40(1) – reinstatement, re‑engagement or twelve months' compensation are alternative and discretionary; Pleadings and proof – CMA Form No.1 as plaint – parties bound by pleadings; Collective Bargaining Agreement entitlements not awardable at revision where unpleaded/unproved; Revisional court not forum for fresh evidence.
15 June 2022
Fixed‑term employee’s dismissal for alleged fighting was substantively and procedurally unfair; CMA award upheld.
* Employment law – unfair termination – substantive and procedural fairness of dismissal for alleged fighting on duty. * Fixed‑term contracts – remuneration determined by contract terms (hourly rate) for compensation calculations. * Disciplinary procedure – requirement to call evidence and avoid procedurally flawed hearings; cross‑examination without applicant’s evidence undermines fairness. * Evidence – corroboration by contemporaneous statements, police records and related criminal findings relevant to employment misconduct disputes. * Judicial review – High Court upholds CMA award where termination is both substantively and procedurally unfair.
13 June 2022
Sickness of the applicant’s legal manager constituted good cause for a seven‑day delay, so extension to file revision granted.
Labour law – extension of time to file revision of CMA award; Section 91(1) ELRA; Lyamuya criteria for 'good cause' – accounting for delay, diligence, inordinate delay; sickness of legal officer as justification.
13 June 2022
Termination was both substantively and procedurally unfair; CMA award upheld and employer's revision dismissed.
Employment law — unfair termination; sufficiency and clarity of disciplinary charge; gross negligence vs ordinary negligence; procedural fairness and bias in disciplinary hearings; remedies for unfair dismissal (compensation, notice, severance).
10 June 2022
Court quashed CMA award and held the respondent's dismissal for forging test results substantively and procedurally fair.
* Labour law – unfair termination – parties bound by their pleadings; arbitrator cannot decide unpleaded issues. * Evidence – oral evidence may be sufficient; absence of documentary corroboration affects weight, not admissibility. * Employment misconduct – processing unregistered test samples, using fictitious templates and wrong barcodes; endangering patient and breaching medical ethics. * CMA award reviewed and set aside where arbitrator misdirected in evaluation of evidence.
10 June 2022
Deficient investigation evidence and absent key witness made bribery unproven; dismissal was substantively and procedurally unfair, reinstatement upheld.
Labour law – unfair dismissal – substantive and procedural fairness; admissibility of investigation reports and electronic evidence; requirement to call key witnesses; adverse inference for failure to call key witness; heightened civil standard for allegations amounting to crime; reinstatement and practicability of remedy.
10 June 2022
The applicant failed to prove misconduct or follow fair disciplinary procedure; the respondent's dismissal was unfair.
Labour law – unfair termination – substantive and procedural fairness; employer’s burden to prove misconduct under ELRA and the Code of Good Practice; probational confirmation and estoppel; right to receive investigation/audit report and to be interviewed; proper composition of disciplinary committee; revision of CMA award.
10 June 2022
9 June 2022
The applicant's retrenchment claims were barred by res judicata; the revision application was dismissed with no costs.
* Res judicata – application where prior proceedings, including Court of Appeal, finally determined same cause of action – Section 9 Civil Procedure Code. * Pleadings – requirement to include whole claim arising from a cause of action – Order II Rule 2 CPC; omission or relinquishment bars subsequent suit absent leave. * Jurisdiction – CMA functus officio where matter already finally decided by competent court.
8 June 2022
Revision application dismissed as time-barred; electronic filing printout contradicted sworn documents and limitation is jurisdictional.
Labour law – Revision of CMA award – Limitation period under Section 91(1)(a) ELRA – Electronic filing proof – Jurisdictional nature of limitation – Article 107A not a basis to evade time limits – Alleged fraudulent filing documentation.
7 June 2022
Failure to account for each day of delay warranted refusal of condonation; alleged illegality and naming errors did not justify extension.
* Labour procedure – condonation/extension of time – requirement to show sufficient cause and account for each day of delay. * Procedural law – illegality as a ground for extension – limits where no clear illegality appears in the impugned ruling. * Civil procedure – doctrine of misnomer/finger litigation – correction of wrongly named parties. * Constitutional/administrative law – right to be heard cannot be asserted where statutory time limits are not observed.
7 June 2022
Omission of an arbitrator's signature to authenticate each witness's evidence nullifies CMA proceedings and mandates rehearing.
Labour law — CMA procedural requirements — oath and affirmation compliance; Rule 19(2) interpretation; arbitrator's signature at end of each witness's evidence — omission fatal; nullification and remittal for rehearing de novo.
7 June 2022
Non-confirmation after probation for repeated lateness was lawful; CMA award for unfair termination quashed.
* Labour law – Probationary employment – Non-confirmation vs termination – Repeated lateness and warnings as fair reason for non‑confirmation; procedural fairness under GN. No. 42 of 2007. * Labour dispute review – CMA award improperly procured where arbitrator mischaracterised non-confirmation as unfair termination.
7 June 2022
Applicant’s reliance on a general provision instead of s.47(3) LDCA rendered the leave application incompetent and it was struck out.
Appeal procedure — certificate/leave to appeal to Court of Appeal where appeal originates from Ward Tribunal — necessity to cite Section 47(3) Land Disputes Courts Act; mis‑citation of enabling provision renders application incompetent; overriding objective cannot cure mandatory procedural defects; application struck out.
6 June 2022
Section 37(5) bars disciplinary action only after criminal charges are before a court, not during police investigation.
Employment law – unfair termination; substantive and procedural fairness; employer duty to prove fairness; Electronic Filing Rules (Rule 21(1)) – date of filing; Labour law s.37(5) – disciplinary action barred only where employee is charged in court; evidence – circumstantial proof and CCTV-related investigative reports.
6 June 2022
General damages are discretionary and need not be strictly proved, but unpleaded, excessive awards will not be granted.
* Labour law – unfair termination – fixed‑term contract terminated early – mediation compensation and arbitral award of statutory entitlements; general damages claim dismissed. * Damages – general damages discretionary – need not be strictly or specifically pleaded like special damages. * Appellate review – interference with discretionary award of damages only where wrong legal principle applied or award is plainly erroneous. * Pleadings – large unpleaded quantum raised in evidence may be rejected as unjust enrichment.
6 June 2022
Arbitrator wrongly admitted contested termination letter at preliminary objection; dispute remitted for full evidential hearing on limitation.
Labour law – jurisdiction – preliminary objection – admissibility of documents at preliminary objection stage – limitation of actions – preliminary objections must be pure points of law not dependent on disputed facts – right to be heard and proof by evidence – striking out vs dismissal of time‑barred matters.
6 June 2022
Presumptive factors in s.61 and the engagement letter established employment; CMA award of reinstatement upheld.
Labour law – employment relationship – s.61 presumption and factors (control, hours, integration, economic dependence) – letter of engagement as evidence; unfair termination – burden on employer to prove fairness and procedural compliance; reinstatement and compensation under ELRA and Code of Good Practice.
3 June 2022
Failure to file the mandatory notice of intention under Regulation 34 GN.47/2017 renders a revision incompetent and is struck out.
Labour law — Revision procedure — Regulation 34 GN. No. 47/2017 — Mandatory notice of intention to lodge revision — "Shall" denotes compulsory compliance — Prior permission to refile does not waive mandatory procedural requirements — Failure to file notice renders revision incompetent and leads to striking out.
3 June 2022
Applicant failed to show sufficient cause for unexplained delay to seek revision of CMA award; extension refused.
* Labour law – extension of time – application to set aside CMA award – statutory 42‑day period under s.91(1)(a) – applicant must account for each day of delay; representative suit or struck‑out applications do not automatically excuse unexplained delay; Rule 56(1) discretionary power exercised judiciously.
2 June 2022
Work-related illness can justify condonation of delay in referring unfair termination disputes to the CMA.
* Labour law – condonation of delay – Rule 10(1) Labour Institutions (Mediation and Arbitration) Rules, 2007 (GN No.64) – applicable time limit for unfair termination referrals; * Principles for extension of time (Lyamuya) – length of delay, reasons, arguable point/illegality, prejudice; * Sickness/work-related illness as sufficient cause for delay – hospitalization not strictly required; * Review of CMA decision – whether retrenchment was genuine in context of occupational illness.
2 June 2022
Applicants' sickness justified a 99-day delay; court granted condonation and ordered the dispute to be heard.
Labour law — condonation for late filing — sufficient cause — sickness and medical evidence as justification for delay; Procedure — preliminary objection under Regulation 34(1) GN No.47/2017 — effect of failure to re-join on determination of objections; CMA review — evaluation of medical reports and inordinate delay standard.
2 June 2022