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.

103 judgments
  • Filters
  • Judges
  • Alphabet
Sort by:
103 judgments
Citation
Judgment date
August 2022
The Court held the termination date was extended to late February 2020, so the CMA referral was timely and the CMA award is set aside.
* Labour law – termination date – effect of employer’s post‑notice conduct/letter extending handover and salary; determination of actual date of termination. * Limitation – Regulation 10(1) Labour Institutions (Mediation and Arbitration) Rules 2007 – counting 30-day referral period from effective date employer made final decision/termination. * Procedure – appropriateness of CMA arbitrator raising limitation suo motu after hearing; remittal to CMA for adjudication on merits. * Civil procedure – revision – setting aside award and remitting record for fresh determination by another arbitrator.
31 August 2022
Non-renewal of a fixed-term contract at expiry is not unfair termination absent an established expectation of renewal.
* Employment law – Fixed-term contracts – automatic termination on expiry – non-renewal not equivalent to dismissal unless expectation of renewal established. * Labour procedure – CMA award review – arbitrator misconceived facts by treating non-renewal as dismissal. * Remedies – unfair termination remedies not available where contract expires; breach remedies relate to remaining contract period.
31 August 2022
Employer's failure to prove abscondment or take disciplinary action rendered the dismissal unfair; CMA award upheld.
* Labour law – unfair termination – employer's duty to take disciplinary/legal action for unexplained absence exceeding five days; burden of proof rests on employer to prove abscondment. * Evidence – absence of documentary proof (warning letter, salary slip) supports upholding CMA finding. * Review – High Court will not revise CMA award where employer fails to rebut employee's claim of unfair termination.
31 August 2022
Court quashed CMA's refusal of condonation, finding delay not inordinate and alleged illegality a sufficient cause for extension.
* Labour law – condonation for late filing – Rules 10, 11 and 31, Labour Institutions (Mediation and Arbitration) Rules, G.N. No. 64 of 2007 – requirements to account for each day of delay. * Extension of time – Lyamuya principles – delay not inordinate, diligence, and existence of illegality as sufficient cause. * Procedural fairness – right to be heard (alleged illegality of suspension and termination) as material to condonation. * Revision – High Court quashes CMA refusal and remits matter for hearing on merits.
31 August 2022
Employer failed to prove valid and fair termination; dismissal upheld and compensation reduced to 12 months.
* Labour law – unfair termination – burden on employer to prove valid reason and fair procedure for dismissal; * Dispute resolution – mediation timeline under s.86(4) ELRA – delay beyond 30 days not automatically fatal; * Procedural irregularity – change of arbitrator without recorded reasons not fatal absent shown prejudice; * Compensation – appellate reduction of excessive CMA award to 12 months’ remuneration.
31 August 2022
Failure to administer oath and record full witness names at CMA vitiates proceedings and mandates rehearing.
Labour law – CMA proceedings – mandatory administration of oath/affirmation to witnesses – failure vitiates proceedings; Witness identification – failure to record full names fatal; Award quashed and matter remitted for rehearing before a different arbitrator.
30 August 2022
30 August 2022
Applicant’s unexplained absence deemed abscondence/self‑termination; no unfair termination proved, revision dismissed.
* Employment law – unfair termination – burden to prove termination – insufficiency of evidence to prove employer‑initiated termination. * Employment law – abscondence/self‑termination – unexplained prolonged absence may constitute resignation by conduct. * Suspension pending criminal investigation – requirement of full pay under Code of Good Practice does not supplant need to prove formal suspension or employer action. * Procedural review – High Court will not disturb CMA award absent error in analysis or insufficiency of evidence.
30 August 2022
Employer failed to prove statutory consultation for COVID‑19 retrenchments; termination found procedurally and substantively unfair.
* Employment law – Retrenchment – Requirement for meaningful consultation and disclosure under s.38 ELRA and Rule 23 Code of Good Practice; * Procedural fairness – need for documentary proof (minutes/records) of negotiations; * Evidence – limits of sole reliance on oral testimony where statutory consultation required; * COVID‑19 – economic hardship must be substantiated for lawful retrenchment.
29 August 2022
Employer failed to prove misconduct or follow procedure; dismissal unfair and twelve months' pay awarded (adjusted).
* Employment law – unfair dismissal – requirement for employer to prove misconduct and compliance with disciplinary procedure; insufficient evidence of theft and insubordination. * Employment law – probation – employer’s duty to produce written contract; absence of contract shifts burden to employer to prove employment terms. * Labour procedure – disciplinary action during pending criminal proceedings – limitations under statute rendering dismissal unlawful. * Remedies – compensation for unfair dismissal – twelve months' salary and proper salary basis for calculation.
29 August 2022
Court found termination unfair, rejected automatic termination, and varied award to correct arrears and contract‑breach compensation.
Labour law – unfair termination – retrenchment and operational requirements – automatic termination (Rule 5(1) Code) – fixed‑term contract breach – calculation of salary arrears and compensation.
29 August 2022
Employer failed to prove fixed-term contracts or lawful dismissal; CMA’s unfair-dismissal award was upheld and appeal dismissed.
* Labour law – unfair dismissal – employer’s burden to prove lawful termination and terms of employment – absence of written contracts or proof of contract duration strengthens finding of unfair dismissal. * Fixed-term contracts – proof of start and end dates required to limit compensation to unexpired term. * Evidence – employer must produce material evidence to rebut CMA findings. * Remedies – compensation for unfair dismissal where procedural requirements not met.
29 August 2022
Applicant failed to show material irregularity; CMA award upholding dismissal for alleged luggage-related misconduct stands.
* Labour law — unfair termination — revision of CMA award — requirement to show material irregularity or lack of reasonable grounds for arbitration award. * Burden of proof — employer's duty to prove fairness of termination under ELRA; use of investigation report and CCTV evidence. * Procedural fairness — failure to impugn disciplinary procedure undermines revision application. * Aviation/carriage regulations — misuse of passenger baggage tags as misconduct justification.
29 August 2022
Sleeping on duty by a security guard is misconduct, but dismissal for a first offence was disproportionate; compensation reduced to six months.
Labour law – Misconduct – Sleeping on duty by security guard as valid reason for discipline – Proportionality of dismissal as sanction – Review and variation of CMA compensation award.
29 August 2022
Whether a fixed-term contract’s stated duration, not months served, determines protection against unfair termination.
Labour law — Fixed-term contracts — Interpretation of contract duration versus months served — Section 35 Employment and Labour Relations Act — Procedural requirements for early termination of fixed-term contracts — Code of Good Practice (G.N. No. 42 of 2007) rule 8.
26 August 2022
A foreign national's employment contract conflicting with permit conditions is void; both parties must secure work permits.
* Employment law – foreign workers – requirement of residence and work permit – validity, duration and conditions of permit govern right to work. * Contract law – agreements contrary to statutory requirements – contracts unenforceable by law are void ab initio. * Labour procedure – effect of lack of legal competence to work on remedies from labour institutions. * Statutory obligation – both employer and employee obliged to obtain permit; contravention criminalized.
26 August 2022
Revision dismissed; CMA award upheld—salary fixed by written contract, NSSF issues not entertained, no severance without 12 months' service.
Labour law – revision of CMA award; admissibility of new issues on revision; evidentiary value of written employment contract versus NSSF contributions; severance pay entitlement requires 12 months continuous service under ELRA section 42.
26 August 2022
Unread admitted documentary evidence must be expunged; remaining evidence must prove the offence beyond reasonable doubt.
Criminal procedure – Documentary exhibits admitted but not read aloud – requirement to read contents; expunction of exhibits; burden of proof – prosecution must prove guilt beyond reasonable doubt; procedural irregularities as ground for nullifying proceedings and quashing conviction.
26 August 2022
Termination for unauthorised absenteeism held substantively fair but procedurally unfair; applicant awarded one month's salary.
Employment law – unfair termination – absenteeism exceeding five consecutive days can constitute fair substantive reason for dismissal; disciplinary fairness – employer must adduce evidence and call witnesses at hearing per Rule 13(5) GN. No. 42 of 2007; where procedure is unfair, compensation may be awarded despite substantive fairness.
26 August 2022
Extension to set aside an ex parte award requires accounting for each day of delay; negligence does not justify condonation.
Labour — extension of time to set aside ex parte award — Rule 31 (Labour Institutions Rules) — Limitation Act 30-day period — requirement to account for each day of delay — negligence vs good cause — illegality must appear on the face of the record.
26 August 2022
Court granted extension of time, finding delay technical from electronic filing and court administrative errors rather than applicant negligence.
* Labour procedure – extension of time – Rule 56(1) LCR – discretion exercised upon sufficient cause shown. * Sufficient cause – technical delay caused by electronic filing/system errors and court administrative directions. * Promptness and diligence – initial timely filing followed by repeated withdrawals/refilings due to system and procedural requirements. * Distinction between technical delay attributable to court/system and delay caused by applicant’s negligence.
26 August 2022
26 August 2022
CMA Ilala had jurisdiction; termination for refusal to work Saturdays was substantively and procedurally fair, arbitrator’s award unjustified.
* Labour law – territorial jurisdiction of CMA – venue of mediation/arbitration and timing of jurisdictional objections. * Employment law – unfair termination – absenteeism for religious reasons versus contractual obligation to work Saturdays. * Procedural fairness – disciplinary procedure, investigation requirement, and right to be heard. * Remedies – entitlement to reinstatement/compensation under section 40 ELRA and review of CMA awards.
25 August 2022
Revision dismissed as time-barred for lacking leave to file beyond the statutory six-week period.
Labour law — Revision of CMA award — Limitation period under section 91(1) ELRA — Leave to file out of time — Time-barred application.
25 August 2022
Working past a fixed-term expiry may create renewal expectation, but under-six-months' service limits compensation.
Employment law – fixed-term contracts – expectation of renewal where employee works beyond expiry (GN No. 42/2007 rule 4(3)); unfair termination remedies and section 35 exclusion for employees with under six months’ service; substitution of CMA award from statutory 12 months to unexpired term.
25 August 2022
Prolonged employee absence and employer inaction can support finding of oral termination and justify reinstatement.
Labour law – unfair termination; jurisdiction of CMA; premature claims; oral termination inferred from prolonged absence and employer inaction; reinstatement and back pay; arbitrator's discretion under s.40(1) Cap 366.
25 August 2022
Direct witness proof of resignation rendered the CMA referral time‑barred; award nullified for lack of jurisdiction.
Labour law – resignation vs unfair termination – proof of authorship of documents by witness who saw writing – doctrine of misnomer/finger litigation – time limits for referral to CMA and jurisdictional consequences of filing out of time without condonation.
25 August 2022
A time-barred revision cannot be withdrawn to circumvent a competence objection; time limits go to the court’s jurisdiction.
Labour law — Revision proceedings — Time limitation under s.91(1)(a) ELRA (42 days) — Competence — Time bar goes to jurisdiction — Withdrawal of time-barred application to refile for extension disallowed.
25 August 2022
A prior strike-out for being time-barred is a final determination and bars refiling under res judicata.
* Civil procedure – res judicata – application previously struck out as time-barred – effect on refiling; application for representative suit; Section 9 Civil Procedure Code; preliminary objection on jurisdiction.
25 August 2022
High Court lacks jurisdiction to revise a Deputy Registrar's execution order; remedy lies by reference, not revision.
Labour law – execution proceedings – jurisdiction – revisability of Deputy Registrar's decisions; procedural remedies – reference under Order XLI Rule 1/CPC and Rule 55(1) Labour Court Rules; dismissal for want of jurisdiction versus striking out; execution costs and form CC.10 issues not reached.
24 August 2022
Failure to administer oath to CMA witnesses vitiated proceedings; award quashed and matter remitted for rehearing.
Labour law – Evidence at CMA – Failure to administer oath or affirmation to witnesses – Mandatory under Rule 25(1) and Oaths Act – Omission vitiates CMA proceedings – Award quashed and matter remitted for de novo hearing.
24 August 2022
CMA lacked jurisdiction because TAZARA employees are public servants required to exhaust PSA remedies before labour claims.
* Labour jurisdiction – public corporations – Whether employees of a statutory public corporation are 'public servants' under the Public Service Act. * Public Service Act s.32A – mandatory exhaustion of administrative remedies before invoking labour law forums. * Effect of statutory staff regulations – do not displace PSA where entity performs public service and is statute-established. * Jurisdiction – CMA deprived of jurisdiction where PSA remedies not exhausted.
24 August 2022
Operational losses justified retrenchment but failure to consult rendered it procedurally unfair; reduced compensation ordered.
* Labour law — Retrenchment — Substantive fairness: operational requirements justified by employer's financial losses (Rule 23(1)); * Labour law — Retrenchment — Procedural fairness: statutory consultation and disclosure requirements under section 38 not discharged; * Evidence — Onus on employer to prove fairness (s.39); * Remedies — Reduced compensation where termination is substantively fair but procedurally unfair; * Authority applied: Felician Rutwaza v World Vision Tanzania (compensation reduction).
24 August 2022
Termination for unpaid children's school fees without investigation was substantively and procedurally unfair; award revised and compensation ordered.
Labour law – termination – employer must prove valid reason related to conduct/capacity and follow fair procedure (s.37 ELRA; GN. No.42 Rule 13). Submissions are not evidence; omission of closing arguments absent prejudice does not invalidate an award (GN. No.67 Rules 25,27). Hearsay insufficient to prove misconduct; alleged non-payment of children’s school fees is not per se a valid employment-related misconduct.
24 August 2022
24 August 2022
Applicant’s challenge to retrenchment dismissed where respondent proved economic need and complied with consultation and payment obligations.
* Labour law – Retrenchment – operational requirements (economic grounds) and evidentiary proof; * Labour law – Procedure – duty to give notice, disclose relevant information and consult (s.38 Employment and Labour Relations Act; GN No. 42 of 2007); * Selection criteria – fairness of selection method and effect of payment/acceptance on challenge to retrenchment; * Burden of proof – financial records and consultation evidence justify lawful retrenchment.
24 August 2022
An application to set aside a compromise court order filed after the 15‑day Rule 38 period is time‑barred and dismissed.
Labour procedure – setting aside consent/compromise decree – Rule 38(1) & (2) GN. No. 106 of 2007 – 15‑day limitation from date of knowledge – time‑bar; preliminary objection – competency of omnibus applications; jurisdictional challenge.
23 August 2022
22 August 2022
22 August 2022
22 August 2022
Resignation given in police custody after employer visit was involuntary, amounting to constructive termination and entitling applicants to compensation.
Labour law – constructive termination — resignation signed in police custody after employer visit — coercion and inducement can render resignation involuntary; remedies for unfair termination (36 months’ compensation and severance).
22 August 2022
Applicant’s admission established substantive reason for dismissal, but lack of investigation and hearing made termination procedurally unfair.
Labour law – termination – substantive fairness established by employee’s admission – procedural fairness requires investigation and disciplinary hearing; closing arguments are not evidence; Rule 26 & Rule 27 GN. No.67/2007; Rule 13 GN. No.42/2007; Section 37 and Section 42(3)(b) Cap.366 R.E.2019.
22 August 2022
Procedural failure to specify the breached rule vitiated termination despite valid misconduct; CMA award upheld for unfair procedure.
Labour law – disciplinary proceedings – language of hearing – availability of translator and employee participation; substantive reason for termination (theft/negligence) vs procedural fairness – need to inform employee of specific rule breached; arbitrator raising new issues suo motu; breach of fixed-term contract turning into unfair termination remedy; compensation for remaining contract period.
22 August 2022
An applicant cannot rely on constructive dismissal at hearing when the CMA form did not plead fairness of termination.
* Labour law – Constructive dismissal/forced resignation – requirement to plead fairness of termination under Part E and section 36 of Cap. 366 R.E. 2019. * Civil procedure – Parties bound by pleadings – inability to advance a different cause at trial without amendment. * Employment law – Fairness of termination requires proof of valid reason and fair procedure (section 37). * Pleading defects – Incompetence of CMA claim where Part B/E not completed for termination claims.
22 August 2022
Court granted condonation where mediator dismissed application without respondent’s counter-affidavit and miscomputed limitation period.
Labour law – limitation period for unfair termination claims; Rule 4 GN No. 64/2007 – exclusion of termination date; condonation – sufficiency of reasons (illness/technical delay); evidentiary requirement – necessity of counter-affidavit to rebut affidavit; appellate review – mediator’s reliance on submissions versus evidence.
22 August 2022
CMA misapplied unfair-termination protections to a probationary employee; High Court quashed the award.
Employment law – Probationary employment – Termination during probation – Applicability of Part B of CMA Form 1 – Section 35 exclusion for employees with less than six months' service – Misapplication of protections for confirmed employees.
19 August 2022
Applicant failed to show good cause or illegality; court dismissed application for extension of time due to hearsay and abuse of process.
* Labour law – extension of time to apply for restoration and revision of arbitral award; requirement to show good cause; distinction between irregularity and illegality. * Evidence – affidavits and counter-affidavits as substitutes for oral evidence; submissions not in affidavit are hearsay. * Civil procedure – abuse of court process and delay as ground for refusal of extension of time. * Practice – necessity of affidavit from third persons named in pleadings (e.g., defaulting advocate) to avoid hearsay.
19 August 2022
Dispute over whether a signed one-year fixed-term contract was varied to two years by unsigned emails; arbitrator's award partly quashed.
Fixed-term employment contracts — contract duration established by signed written agreement — unsigned/unauthenticated emails cannot vary a signed contract; notice of non-renewal ends contract at expiry; award for unproven remaining term quashed; award for unpaid salary upheld.
19 August 2022
Applicant confirmed after probation; dismissal for failed salary negotiations was substantively unfair, awarding pay for unexpired contract and notice.
Labour law – unfair termination – effect of continued employment after probation – fixed‑term contract – entitlement to unexpired contract salary and notice pay when dismissal is substantively unfair.
19 August 2022
Resignation takes effect from its stated date; respondent failed to prove constructive dismissal, CMA award largely quashed.
Employment law – Constructive dismissal – Requirements for constructive termination (resignation, intolerability, employer causation) – Resignation effective from date stated; no duty on employer to accept in writing – Newspaper publication of cessation not necessarily unfair termination.
19 August 2022