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.

24 judgments
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24 judgments
Citation
Judgment date
November 2023
Revision improper; appeal under Workers' Compensation Act required and Board of Trustees is a necessary party.
Workers' compensation — procedure — conflict between statutory appeal (s.80(2) Workers' Compensation Act) and subsidiary regulation (Reg.29(3)) — principal Act prevails; Necessary party — Board of Trustees of Workers Compensation Fund must be joined where Fund liabilities are affected; Representation — notice must be signed by the party (Rule 43); Form and service requirements — compliance with Rule 24 (notice) and Rule 46 (index/pagination) required though some defects may be curable under overriding objective; Remedy — strike out (not dismissal) to permit proper refiling.
30 November 2023
Applicant who accepted retrenchment package is estopped from challenging retrenchment's validity and procedures.
Employment law – retrenchment – substantive fairness (operational requirements/losses) – procedural fairness – consultation and acceptance of retrenchment package – issue estoppel – requirement to pursue mediation under s.38 Employment and Labour Relations Act – arbitrator's reliance on oral evidence.
29 November 2023
Fixed-term contract expired by its terms; arbitrator erred by deciding unpleaded legitimate-expectation issue and award was quashed.
Employment law – fixed-term contract – renewal only by mutual agreement – contract expires automatically on expiry date (Rule 4(2) GN. No. 42/2007). Employment law – notice of non-renewal is not necessarily termination; may be a courtesy where expiry date known. Civil procedure – arbitrator raising unpleaded issues suo motu – duty to afford parties opportunity to be heard; decision-maker bound by pleadings. Remedies – reinstatement and back pay inappropriate where contract expired by effluxion of time and unfair termination not proved.
29 November 2023
An improperly signed clarification application led an arbitrator to exceed jurisdiction by revising, not clarifying, a CMA award.
Labour law – CMA procedure – Notice of application must be signed by the party (Rule 29 GN. No.64 of 2007); Clarification of award is distinct from revision or calculation; Arbitrator lacks jurisdiction to revise fellow arbitrator’s award or assume executing officer’s functions.
29 November 2023
Sickness inadequately proven and negotiations do not suspend limitation; condonation refused and revision dismissed.
Labour law – condonation of time for filing unfair termination disputes; sickness as ground for extension – requirements for evidence; duty to account for each day of delay (Lyamuya principle); pre‑court negotiations do not stop running of limitation period.
28 November 2023
Affidavit attested abroad by an advocate not authorised under Tanzanian law is defective; application struck out.
Notaries and commissioners for oaths – Foreign attestation – Jurat – Cap 12 R.E. 2019 – Foreign advocate has no automatic right to practise as notary/commissioner for oaths in Tanzania – Authentication of foreign affidavits by Registrar required.
28 November 2023
28 November 2023
24 November 2023
Technical delay and prompt action justified 14-day extension to file CMA F10 for intended revision.
Labour law – extension of time – notice of intention to seek revision (CMA F10) – Regulation 34(1) GN No.47 of 2017 – mandatory forms – technical delay where original revision filed in time – promptness and prevention of double punishment – illegality issue reserved for revision.
17 November 2023
Alleged illegality of termination and non-payment of terminal benefits justified extension of time despite inordinate delay.
Labour law – condonation/extension of time – when alleged illegality (e.g., unlawful termination and non-payment of terminal benefits) justifies extension despite inordinate delay. Procedure – right to be heard – arbitrator must consider substantive allegations and reasons for delay. Precedents – Lyamuya (accounting for delay) and Valambia (duty to investigate alleged illegality).
17 November 2023
Fixed-term contract renewed by default where employee continued working and was paid; CMA award varied, leave claim disallowed.
Labour law – Fixed-term contracts – automatic (default) renewal where employee continues working after expiry and is remunerated. Evidence – admissibility and inference: non-admission of bank statement does not preclude drawing inference from other evidence and parties' conduct. Statutory guidance – Rule 4(3) GN 42/2007 and s.61 Labour Institutions Act factors for establishing employment relationship. Remedies – variation (not quash) of CMA award where a component (leave allowance) lacks proof; reduction of award accordingly. Procedural – High Court may exercise revisional jurisdiction to vary CMA awards when grounds are established.
17 November 2023
Adjudicator may decide extension applications; a death certificate alone does not prove sufficient cause for late filing.
Labour — Extension of time — Jurisdiction of adjudicator under T.S. No.64/2004 — Sufficiency of cause — Death certificate alone insufficient to prove caregiver-related delay — Burden to explain each day of delay and produce corroborative evidence.
15 November 2023
A challenge to the CMA's grant of condonation is interlocutory and premature for revision; file remitted to CMA.
Labour law — Condonation at CMA — Interlocutory order — Revision premature — Rule 12(1)(2)(c) GN. No.64/2007; Rule 50 Labour Court Rules — Test: does order finally dispose of parties' rights?
14 November 2023
CMA award of unpaid salaries for alleged sickness/abscondment quashed for absence of medical proof and evidential basis.
Labour law – absenteeism and entitlement to sick pay; Section 32 ELRA – requirement of medical certificate for sick leave protection; GN. No. 42/2007 Rule 13(6) – disciplinary hearing in employee’s absence; distinction between withholding salary and lawful deduction (Section 28); review of CMA award for lack of evidential basis.
14 November 2023
Court quashed CMA award, finding the respondent’s termination substantively and procedurally fair for serious negligence.
Employment law – unfair dismissal – substantive fairness – serious negligence in preparing invoice advice and releasing containers without full payment. Employment law – procedural fairness – notice, hearing, admission at disciplinary hearing, and requirement (or not) for prior investigation. Review of arbitral award – superior court interference where lower tribunal misapplies law or discretion. Interpretation and application of GN No. 42 of 2007 (Code of Good Practices) and employer code of conduct.
14 November 2023
A registered union’s statutory right to enter workplace for recruitment and meetings is enforceable; fines must be imposed by lower courts.
Labour law – Trade union organizational rights – s.60 ELRA – right to enter employer premises to recruit, communicate and hold meetings; notice under s.64 (TUF14). Compliance and obstruction – Employer’s unjustified refusal to allow union access unlawful. Jurisdiction – Imposition of statutory penalties under ELRA reserved to District/Resident Magistrate’s Courts (s.102(1)).
10 November 2023
A CMA grant of condonation is interlocutory; revision must await final determination of the substantive dispute.
Labour law – Condonation for late referral to CMA – Whether condonation decision is interlocutory or final – Rule 50 Labour Court Rules – Section 86 ELRA – Avoidance of piecemeal litigation and promotion of expeditious labour dispute resolution.
10 November 2023
CMA Ilala lacked territorial jurisdiction because the cause of action arose in Mwanza; the CMA award is nullified.
Labour law – territorial jurisdiction of CMA – cause of action must be determined by locus where misconduct and supporting evidence arose; referral must be filed at CMA office responsible for that area unless the Commission directs otherwise – disciplinary venue at employer’s Head Office does not shift territorial jurisdiction.
10 November 2023
A CMA order granting condonation is interlocutory and not subject to revision until final determination.
Labour law – condonation – CMA condonation orders treated as interlocutory and not subject to revision before final determination – Rule 11(2) GN No. 64/2007 – Rule 50 LCR – objectives of speedy and inexpensive labour dispute resolution; right to be heard.
9 November 2023
8 November 2023
Alleged illegality does not automatically justify a five-year extension; applicant must account for all delay and show diligence.
Civil procedure – extension of time – applications to lodge notice of appeal – principles from Lyamuya and Valambhia – illegality must be apparent on the face of record. Delay – applicant must account for all days of delay; delay must not be inordinate; must show diligence. Conduct – pursuing multiple remedies and withholding material facts may defeat an extension of time.
7 November 2023
Applicant's re‑enrolment of execution dismissed as time‑barred under Item 21 Part III of the Law of Limitation.
Labour procedure — re‑enrolment of execution — absence of prescribed time limit in labour rules — recourse to general limitation law under Rule 55 LCR. Law of Limitation Act — Item 21 Part III — 60‑day limitation for actions where no period provided. Limitation as jurisdictional bar — time‑barred applications to be dismissed; no sympathy or equity applies. Remedy for late filing — dismissal under the Law of Limitation Act (s.3(1)).
7 November 2023
Proceedings where a tribunal hears merits before deciding a timely preliminary objection on limitation are null and must be remitted for retrial.
Labour law — Procedural law — Preliminary objections — Time limitation — A tribunal must determine preliminary points of objection (including limitation) before hearing merits; failure to do so renders proceedings and decision nullity and warrants remittal for retrial before a different arbitrator.
7 November 2023
Court upheld lifting of corporate veil and ordered applicant’s detention to enforce unpaid decretal sum.
Company law – lifting corporate veil – directors’ liability where company refuses to honour decretal award; Civil procedure – execution by arrest and detention under Sections 42, 44 and Order XXI of the Civil Procedure Code – requirements for show-cause summons and committal; Joinder/name error – curability and appellate remedy; Execution practice – when piercing corporate veil is appropriate to satisfy judgment.
3 November 2023