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.

72 judgments
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72 judgments
Citation
Judgment date
July 2022
CMA proceedings vitiated by omission of witness name and unsworn testimony; award quashed and retrial ordered.
Labour law – CMA proceedings – omission to record witness’s name; unsworn testimony – mandatory oath/affirmation requirement – proceedings vitiated; High Court’s revision jurisdiction – nullification and retrial de novo; inherent powers not available to cure statutory procedural defects.
29 July 2022
The applicant's non-payment of one month's salary was a breach; the court reduced the CMA's six-month award to two months' pay.
Labour law – breach of fixed-term employment contract; non-payment of salary as breach; distinction between breach and unfair termination; review/revision of CMA awards; assessment and rationality of quantum for damages.
29 July 2022
Court upheld CMA award: dismissal substantively unfair due to contributory employer failings, but procedure was fair; 12 months' compensation affirmed.
Employment law — unfair termination — substantive fairness (valid reason) — procedural fairness (investigation, right to be heard) — contributory employer negligence and staff shortages — compensation under s.40(1)(c) ELRA — employer's discretion in calling witnesses.
29 July 2022
Employer failed to prove substantive or procedural fairness for dismissal; CMA award and compensation confirmed.
Labour law – unfair termination – substantive and procedural fairness – employer bears burden to prove valid reason and follow investigation/disciplinary procedure (s.37(2) Cap.366; Rule 13 GN. No.42). Evidence – hearsay and absent witnesses inadmissible to prove dismissal grounds. Remedies – compensation based on proved salary; award and certificate of service upheld. Closing submissions – late-filed submissions are not evidence and non-consideration does not necessarily amount to partial hearing.
29 July 2022
Applicant granted 14 days to file revision because lack of service and denial of hearing constituted a sufficient illegality.
* Labour law — extension of time to apply for revision under Rule 56(1) — requirements for 'sufficient reasons'.; * Procedural fairness — service of summons and right to be heard — ex parte award caused by lack of service to one of the parties.; * Illegality — denial of hearing as ground for extension of time; * Evidence — submissions from the bar not substituting sworn evidence; * Labour Institutions (Mediation and Arbitration) Rules — obligations on service of process.
29 July 2022
The court dismissed the employer’s revision, finding retrenchments substantively and procedurally unfair for lack of notice, disclosure and consultation.
Labour law – retrenchment – substantive justification for retrenchment; procedural fairness – notice, disclosure and consultation under s.38 ELRA and Rules 23–24 Code of Good Practice GN.42/2007; employer’s burden to prove integrity of retrenchment process; review of CMA award.
29 July 2022
Court upheld termination by mutual agreement and dismissed the applicant’s revision for lack of merit.
Employment law – Termination by mutual agreement – Validity of written mutual termination agreement; Contract law – free consent and voluntariness; Review of CMA award – appellate scope limited where agreement established.
29 July 2022
Employer failed to prove lawful suspension; termination was procedurally and substantively unfair, warranting compensation and a service certificate.
Employment law – termination vs suspension; burden of proof on employer; suspension requires compliance with Rules 27(1)–(3), GN No. 42/2007 (written suspension letter and investigation); uncorroborated/hearsay evidence cannot establish lawful suspension; remedies for unfair termination include compensation and certificate of service.
29 July 2022
Revision granted; CMA award quashed for lack of proof of vehicular negligence and employment status, no costs.
* Proof of causation in road accidents – requirement for competent accident and vehicle inspection reports to establish vehicular defect or driver negligence. * Burden of proof – he who alleges must prove, including employment relationship in claims for workplace deaths. * Employment status – administrators must prove deceased were employees to claim under employment law. * Alternative remedies – availability of third‑party motor insurance where tortious liability is not established. * Evidence of injury – need for medical/contemporaneous documentation to substantiate personal injury claims.
28 July 2022
E-filing date governs limitation; electronic filing printout sufficed and the revision application was timely filed.
* Labour law – revision of CMA awards – limitation period under section 91(1) ELRA (42 days); * Electronic filing – Rule 21(1) GN. No. 148/2018 – e-filing timestamp governs computation of time; * Evidence – system printout of electronic filing accepted as sufficient proof of filing date; registry endorsement not decisive where e-filing record exists.
28 July 2022
Structural business changes and consultation with a recognized union can justify retrenchment if statutory procedure is followed.
Labour law – retrenchment – operational requirements may be based on structural needs alone; consultation – recognized trade union consultation suffices where employees are union members; employer’s duty to prove valid reason and fair procedure; appellate review of CMA award.
26 July 2022
Where an employee is dismissed during probation for poor performance, breach of contract and payment for the remaining term are not automatically warranted.
Labour law – fixed-term contract – probation – termination during probation; pleading discipline – parties bound by pleadings; unfair termination v. breach of contract; relief for termination during probation.
25 July 2022
High Court quashed DLHT appeal and execution orders for procedural irregularities and failure to comply with Regulation 30.
* Land law – execution of decrees – obligation of DLHT Chairman to consider broker's report and formally close execution under Regulation 30. * Procedural irregularity – conflicting DLHT orders and execution in favour of both parties. * Appeals – competency and time limits for appeals from Ward Tribunal to DLHT; need to address assessors' opinion and give reasons for departure. * Locus – institution of proceedings by a person prior to formal appointment as administrator to preserve deceased’s estate may be justified in appropriate circumstances.
25 July 2022
Extension of time to file labour revision denied for unexplained delay and counsel's negligence.
Labour procedure – extension of time to file revision; requirement to account for each day of delay; negligence of counsel not sufficient cause; alleged illegality must be apparent on face of record; prejudice to respondents and interests of justice considered.
25 July 2022
Condonation granted for unpaid-salary claim due to continuing breach and custodial interruptions; matter remitted to CMA for merits.
Labour law – condonation/extension of time – limitation in salary claims – continuing breach doctrine – effect of custodial/remand periods and prosecutorial processes on delay – discretion to grant condonation and remit matter to CMA for merits determination.
24 July 2022
Whether an arbitrator may re-open a preliminary jurisdictional objection already decided by the same tribunal and contrary to a High Court order.
Administrative law; labour law – functus officio – re-opening of previously decided preliminary objections by same tribunal; compliance with superior court orders; limits of revision where prior orders have directed proceedings to continue on merits; procedural objections versus jurisdictional questions.
22 July 2022
Applicants failed to prove sufficient cause for condonation; delay unaccounted and alleged illegality not apparent on record.
Labour law — condonation for late referral — applicant must account for each day of delay and provide evidence of negotiations; illegality must be apparent on the face of the record to justify extension of time; procedural irregularities and submissions’ length do not automatically vitiate condonation decision.
22 July 2022
Applicant’s dismissal for involvement in bribery and failure to report was substantively and procedurally fair; revision dismissed.
Labour law – unfair termination – burden of proof on employer (s.39 ELRA); fair reason for dismissal – misconduct/ bribery and failure to report (s.37(2)); procedural fairness – investigation, suspension, show-cause, disciplinary hearing (GN No.42/2007 rules 9 & 13); disciplinary committee’s role – investigation and recommendation not final decision; review of CMA award – no merit.
22 July 2022
A defective CMA Form conflating termination and unfair labour practice led the High Court to set aside the CMA award and proceedings.
Labour law — Pleadings — CMA Form No. 1 defective for combining termination and unfair labour practice; Procedural irregularity — remedies for termination cannot be awarded where termination claim was dropped; Award set aside and CMA proceedings nullified; Leave to refile limited to unfair labour practice.
22 July 2022
Fixed-term contracts end on expiry; reasonable expectation of renewal requires objective evidence; CMA non-endorsement not fatal.
Labour law – fixed-term contracts – automatic termination on expiry; reasonable expectation of renewal requires objective basis (previous renewals insufficient); non-endorsement of exhibits at CMA not fatal where documents admitted without objection; issues framed from referral and opening statements do not constitute suo motu determination.
22 July 2022
CMA lacked jurisdiction over time‑barred employment claims filed without condonation; award nullified and set aside.
Labour law – limitation periods – Rule 10(2) & Rule 11 GN No. 64 of 2007 – failure to seek condonation – jurisdiction of CMA – time‑barred claims render award void; trial de novo inappropriate where tribunal lacked jurisdiction.
22 July 2022
Employer failed to prove operational retrenchment or comply with consultation rules; dismissal found substantively and procedurally unfair.
* Employment law – unfair termination – retrenchment for operational requirements – employer's burden to prove economic necessity and linkage to dismissal. * Labour procedure – statutory consultation and disclosure under s.38 Employment and Labour Relations Act and Rule 23 GN. No. 42 of 2007 – procedural and substantive obligations. * Evidence – submissions are not evidence; need for documentary/credible proof of hardship and selection criteria. * Relief – upholding CMA award for unfair dismissal (compensation).
22 July 2022
Revision dismissed: applicants bound by CMA pleadings; arbitrator properly found release agreements and payments extinguished claims.
Labour law – fixed-term contracts – early release agreements and payment for remaining period – pleadings and admissible evidence – inability to raise unpleaded claims on revision – submissions not evidence.
22 July 2022
An omnibus application combining extension of time and revision is incompetent and must be struck out; extension must be obtained first.
Labour procedure – omnibus applications – combining application for extension of time and application for revision – competency – extension must be obtained before filing revision; omnibus applications combining separately governed remedies are incompetent.
22 July 2022
Application for extension struck out because applicant lacked locus after changing name without obtaining leave of court.
Labour — Extension of time — Locus and party competence — Change of party name/substitution requires leave of court — Citing CRDB Bank Plc v Kilindi — Filing under new name without leave is fatal.
22 July 2022
Termination was substantively and procedurally unfair due to lack of proof and a biased disciplinary hearing.
Employment law – unfair dismissal – employer's burden under s.39 ELRA to prove valid reasons; procedural fairness – impartial chairperson required (G.N. No.42 Guideline 4(2), 4(7)); insufficiency of hearsay and uncorroborated evidence; remedies – s.40(1)(c) compensation and s.44(2) certificate of service.
21 July 2022
Court upheld dismissal as substantively and procedurally fair based on circumstantial evidence and prior hearing.
Labour law – dismissal for alleged theft – circumstantial evidence and CCTV – substantive fairness; procedural fairness – right to be heard vs denial of internal appeal; review of CMA award.
20 July 2022
Service of notice of intention to seek revision is not required for the applicant's extension-of-time application.
Labour procedure – preliminary objection – requirement to serve notice of intention to seek revision – applicability to extension of time applications – preliminary objection must raise a pure point of law (Mukisa Biscuit principle).
20 July 2022
Fixed-term employee unlawfully terminated; entitled to remaining contract pay and notice pay; severance not payable.
Labour law – Termination by agreement vs unfair termination – Fixed-term contracts – Automatic renewal – Entitlement to unexpired contract remuneration and notice pay – Severance pay not payable for fixed-term contracts under Section 43 ELRA – Remuneration includes allowances.
20 July 2022
Proceedings and award set aside where CMA failed to determine admissibility of a disputed termination document before deciding the case.
Evidence — Admissibility of documents — Disputed signatures/thumbs — Order for forensic examination — Procedural fairness and right to be heard — Proceedings and award nullified where admissibility not determined — Remittal to CMA.
20 July 2022
Retrenchment upheld: employees’ work was project‑dependent and retrenchment procedures and payments were proper.
Labour law – Retrenchment – substantive fairness where employment contingent on a client project – procedural fairness – consultation and notice – improperly filed supplementary affidavit struck out.
20 July 2022
Accused convicted of manslaughter after an unequivocal guilty plea; sentence reduced and remaining term conditionally discharged for good behaviour.
* Criminal law – Manslaughter – Plea of guilty – voluntariness and effect of unequivocal plea – conviction on plea. * Evidence – Post-mortem report – cause of death (brain injury) supports manslaughter conviction. * Sentencing – mitigation for first offender, early guilty plea, time in custody – application of reductions and conditional discharge. * Self‑defence/necessity context – intervening to stop an armed, violent person considered in mitigation.
20 July 2022
Court granted extension to file revision, finding registry delay amounted to sufficient cause for the applicant's late filing.
* Extension of time – discretionary relief – requirement of sufficient cause – registry delay as reasonable cause. * Civil procedure – filing and registration of documents – failure by registry to process filings may justify extension. * Ex parte hearing – respondent served but absent.
20 July 2022
Extension of time denied where delay unaccounted, alleged illegality not apparent on record, and application was an afterthought.
Labour — Extension of time to institute revision — Need to account for each day of delay; illegality must be apparent on the face of the record to justify extension; mere chance of success or assertion of no prejudice is insufficient; inordinate delay and negligence defeat an extension application.
19 July 2022
Respondent's abusive language justified dismissal substantively, but procedural defects reduced compensation to six months.
* Labour law – unfair dismissal – distinction between substantive fairness (valid reason) and procedural fairness (right to be heard). * Misconduct – abusive language and threat ("mjinga", "nitakufanya kitu kibaya") as serious misconduct justifying dismissal. * Procedural fairness – requirement to inform employee of all charges; breach of natural justice vitiates procedure. * Remedies – reduction of compensation where termination substantively justified but procedure defective.
19 July 2022
Extension of time granted due to technical delay and arguable illegality regarding probationary employees' entitlement.
Labour law — extension of time to file appeal; technical delay (struck out appeal) — Fortunatus Masha; apparent illegality on face of record — probationary employment, applicability of s.35 and s.40(1)(c) Employment and Labour Relations Act; appellate discretion to extend time.
19 July 2022
Failure to administer oath or affirmation at CMA nullifies proceedings and requires a rehearing before a different arbitrator.
Labour law – arbitration procedure; administration of oath/affirmation mandatory; arbitrator’s power under s.20(1)(c) and Rule 19(2); Oaths and Statutory Declarations Act s.4(a) and Rule 25(1); procedural irregularity—nullification and trial de novo.
19 July 2022
An ex-parte arbitration award may be set aside where the absent party proves sufficient cause, such as bereavement.
Labour law – Arbitration – Ex-parte hearing under s.88(8)(a) ELRA – Setting aside ex-parte award – Sufficient cause and bereavement – Right to be heard – Remittal for inter-partes hearing.
19 July 2022
Where locus-in-quo procedures and evidence are defective, ownership/boundary disputes require retrial with fuller pleadings.
Land law – boundary and ownership disputes; locus in quo inspections – proper procedure and evidential weight; insufficiency of evidence where key witnesses absent; retrial warranted where tribunal’s procedures and findings are defective.
17 July 2022
Applicant's post-dismissal extension application was an abuse of process; court dismissed it and awarded costs.
Labour procedure — extension of time after dismissal — court lacks jurisdiction to extend time once revision dismissed as time-barred; abuse of process — multiple refilings and successive extension applications; costs — s.50(7) Labour Institutions Act allows costs where proceedings are frivolous or vexatious; preliminary objections — other grounds not decided once primary objection sustained.
15 July 2022
Court held submissions are not evidence and granted condonation based on uncontroverted medical evidence, remitting the dispute to the CMA.
Labour law – condonation for late filing – requirement to account for delay; Evidence – submissions from the bar are not evidence; Procedural law – absence of counter‑affidavit leaves affidavit evidence uncontroverted; Judicial discretion – granting condonation where sickness and medical reports justify delay.
15 July 2022
A probationary termination bars entitlement to remaining fixed-term compensation; parties are bound by their CMA pleadings.
* Employment law – Probation – Termination during probation – Confirmation is not automatic; termination during probation bars entitlement to contractual remainder compensation. * Labour procedure – Pleadings – Parties are bound by their CMA pleadings and cannot change the basis of dispute at revision. * Procedural fairness – Rule 10 GN. No. 42/2007 – Claimant must plead unfair labour practice relating to probation to rely on Rule 10 remedies. * Evidence evaluation – Court will not fault arbitrator absent mis-evaluation on the record.
15 July 2022
Procedural failures (no oaths, improper reassignment, inadmissible exhibits) vitiated CMA proceedings; award quashed and rehearing ordered.
Labour law — procedural fairness — mandatory oath/affirmation for witnesses; arbitration reassignment without reasons or Commission consent; failure to allow party to comment on documentary exhibits — proceedings nullified and award set aside; order for rehearing before different arbitrator.
15 July 2022
Evidence failed to prove termination; CMA award quashed despite exhibit's admissibility.
Labour law – unfair termination – admissibility vs probative value of electronic evidence – authentication under Electronic Transactions Act – estoppel for failure to object – requirement of proof of termination before award.
15 July 2022
Fixed‑term employee unfairly terminated; re‑engagement inappropriate, court awards pay for remaining contract period.
Employment law – fixed‑term contract – unfair termination – hearsay evidence – procedural fairness – bias/pre‑determination at disciplinary hearing – remedy: compensation for unexpired fixed‑term rather than re‑engagement.
15 July 2022
Appellant failed to prove competing ownership; respondent’s allocation and uninterrupted possession upheld, appeal dismissed with costs.
* Land law – ownership dispute – allocation by family head v. claim of estate ownership.* Civil evidence – burden of proof under s.110 Evidence Act; standard on balance of probabilities (s.3(2)(b)).* Hearsay – weight and insufficiency to prove ownership in absence of direct evidence.* Possession – peaceful uninterrupted occupation as evidential weight.* Appellate review – tribunal's factual findings upheld where evidence favored respondent.
15 July 2022
Dismissal for insubordination to an acting manager was substantively and procedurally fair; revision dismissed.
Employment law – unfair dismissal – insubordination to an acting manager; validity of acting authority despite permit limitations; disciplinary procedure – Rule 13 G.N. No. 42/2007 – notice and properly constituted committee; revision of CMA award on grounds of substantive and procedural unfairness.
15 July 2022
Dismissal for alleged gross dishonesty was substantively unfair where employer’s code prescribed a warning for a first offence.
Labour law – unfair termination – gross dishonesty – proof of misconduct under s.39 ELRA and Rule 12(3)(a) Code of Good Practice – employer’s Code of Conduct governing sanctions – proportionality of dismissal – admissibility/weight of SMS admission.
15 July 2022
Retrenchment without personal consultation of a non-union managerial employee was procedurally unfair; CMA compensation upheld.
* Labour law – Retrenchment – statutory duty to consult – Section 38(1)(d) ELRA – personal consultation required where employee not represented by registered trade union. * Employment relations – managerial staff – non-union status – employer’s consultation obligations. * Remedies – procedural unfairness – compensation for failure to consult – CMA award upheld.
15 July 2022
Whether compensation for unfair termination should be calculated from the contract-stated net salary or from basic wage under ELRA.
Labour law – unfair termination – compensation for unexpired term – calculation of wages versus allowances – interpretation of employment contract – s.4 Employment and Labour Relations Act.
14 July 2022