High Court Land Division

High Court Land  Division was established as a result of the land reforms which were implemented by the Land Act 1999. Until 2010, the Land Court had exclusive jurisdiction to determine land disputes relating to land with a pecuniary value of TZS 50,000 or more. 

466 judgments
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466 judgments
Citation
Judgment date
April 2020
Leave to appeal granted where alleged illegality in ex parte proceedings denied applicant right to be heard.
Land procedure – leave to appeal under section 47(1) Land Courts Disputes Act – ex parte proceedings – service of summons – right to be heard – illegality as ground for leave to appeal.
9 April 2020
A non-party cannot nullify a recorded consent settlement by fresh suit; objection must be filed in the originating court.
Civil procedure – jurisdiction – challenge to consent settlement recorded under Order XXIII r.3 CPC – appropriateness of fresh suit versus objection proceedings under Order XXI r.57. Execution proceedings – attachment of property – rights of third parties and investigatory powers of the court under Order XXI r.57 CPC. Consent judgments and recorded deeds – comity between divisions of the High Court and finality of recorded settlements. Allegations of fraud – necessity of pleading particulars and proper remedy in originating court.
9 April 2020
Late submissions filed without leave may be disregarded, leading to dismissal of preliminary objections for want of prosecution.
Civil procedure – preliminary objection – competence of documents – requirement for drawer's name and address under Advocates Act s.44(2); Civil procedure – consequences of non-compliance with court orders – written submissions filed out of time without leave may be disregarded; Failure to prosecute – late filing equated to failure to appear and may lead to dismissal of objections.
6 April 2020
Applicant failed to establish prima facie case, balance of convenience, or irreparable harm; injunction refused and application dismissed with costs.
Civil procedure – Temporary injunctions – Requirements: prima facie case, balance of convenience, irreparable injury – Atilio v Mbowe/American Cyanamid principles. Mortgages – Sale of mortgaged property – Necessity of proper default notices and publication when personal service fails. Banking law – Protection of creditor’s interest and public interest in recovery of loans; prejudice to bank from interlocutory stay. Discretionary relief – Injunction refused where debtor admitted default and procedural requirements for sale were met.
6 April 2020
Applicant failed to prove sufficient cause for extension of time; application struck out as premature and unsupported.
Land law — extension of time to appeal — discretion under section 41(2) Land Disputes Courts Act — sufficient cause required; Limitation law — computation of appeal period — section 19(2) Law of Limitation Act; procedural law — facts must be pleaded in affidavit; negligence/inaction is not sufficient cause.
6 April 2020
Objection to attachment dismissed for failing to prove the registered plot was the land subject to the decree.
Civil Procedure – Order XXI r.57 CPC – Objection to attachment – Objector must prove interest or possession at date of attachment. Evidence – Requirement to establish nexus between registered title and land described in decree before vacating execution. Locus – Power of attorney to transfer property includes authority to commence or defend proceedings related to that transfer.
6 April 2020
A non‑party lacks locus to seek review; application for extension of time struck out as incompetent and res judicata.
Civil Procedure — Review jurisdiction (Order XLII CPC) — Locus standi — Non‑party cannot apply for review; Extension of time requires competence to pursue the intended remedy; Res judicata and conclusive effect of objection order (Order XXI r.62 CPC).
6 April 2020
Applicants who accepted compensation and vacated land cannot later challenge the valuation without proof of underpayment.
Land acquisition – valuation and compensation – participation of landowners in valuation – use of government valuation rates – requirement to tender evidence for subsequent re-valuation – estoppel after acceptance of compensation.
3 April 2020
An eviction without serving the statutory one-month notice is unlawful; personal hardship does not justify non-compliance.
Land law – landlord and tenant – eviction – requirement to serve one-month notice where rent unpaid (Land Act, s.88(2)(b)(i)) – eviction without statutory notice unlawful. Civil procedure – timeliness of appellate written submissions – certification by tribunal establishes timely filing. Equity versus statutory compliance – personal hardship does not excuse non-compliance with eviction procedures.
1 April 2020
March 2020
Negligence of the applicant's counsel does not justify re-admission of an appeal dismissed for want of prosecution.
Civil procedure — Restoration of appeal dismissed for want of prosecution — Application under Order XXXIX Rule 19 CPC. Affidavits — Content limited to facts — Order XIX Rule 3(1) CPC — Affidavit containing law, prayers and arguments is defective and expunged. Evidence vs submissions — Expungement of counter-affidavit does not make application unopposed; submissions are not evidence. Negligence of counsel — Not a sufficient ground to re-admit an appeal or extend time; applicant must show diligence.
26 March 2020
Prior lawful occupation and purchase protect an owner from losing land through later demarcation absent compensation.
Land law — ownership and possession — prior occupation and deeds vs later municipal demarcation; Evidence Act sections 110(1) and 119 — burden of proof where ownership in dispute; Demarcation/allocation — inclusion into later parcel does not divest earlier owner absent compensation or lawful process; Appellate review — weight to ward tribunal records and municipal surveyor’s report.
25 March 2020
Public auction of mortgaged property without 14 days’ notice is void; purchaser lacks s.135 protection absent registration.
Auctioneers Act s.12(2)-(3) — mandatory 14‑day public notice for immovable property auctions; failure vitiates sale; Mortgagee power of sale; Land Act s.135 protection requires registration; Procedural correction of litigant’s capacity; Limitations on spouse/spousal‑consent challenges by administratrix.
24 March 2020
Applicant’s illness and police loss report of stolen medical records constituted good cause to extend time to file appeal.
Extension of time – good cause – discretionary relief – factors include length of delay, reasons, prejudice and arguable appeal. Proof of delay – medical incapacity substantiated by police loss report of stolen medical records deemed relevant. Age of litigant – advanced age as factor in considering inherent slowness and excuse for delay. Exercise of judicial discretion – balance of prejudice and right to be heard supports granting extension.
24 March 2020
Commissioner for Lands is a necessary party in land disputes with conflicting allocation documents; suit struck out for non-joinder.
Civil procedure – Necessary party – non-joinder – Order I r.9 CPC – exception in land ownership disputes Land law – allocation documents, offers and title deeds in different names – Commissioner for Lands as mandated allocating authority Pre-trial procedure – requirement of 30-day notice before instituting suit against a government institution
24 March 2020
Objection under Order XXI requires an actual attachment in execution; application premature and struck out with costs.
Civil Procedure – Objection proceedings to attachment – Order XXI Rules 57(1),(2) and 59 CPC – Mandatory pre-conditions: attachment, execution proceedings, and stranger to the suit. Procedural law – Prematurity of application – No attachment/execution pending renders objection proceedings incompetent. Limitation and affidavit defects – unnecessary to determine once application found incompetent under Order XXI.
23 March 2020
Delay not fully explained, but alleged illegality (respondent's locus standi) justified a 14‑day extension to file appeal.
Land law – extension of time under s.38(1) Land Disputes Courts Act – requirements of good and sufficient cause – need to account for each day of delay and demonstrate diligence. Civil procedure – delay in supply of certified copy – not automatically excusing unexplained pre-request delay. Illegality principle (Valambia) – alleged illegality (locus standi) can justify extension of time to enable appellate determination.
23 March 2020
Applicant failed to prove marriage; property not matrimonial and mortgagee’s affidavit satisfied regulatory due diligence, appeal dismissed.
Land law – mortgage of land – requirement of spouse consent where property is matrimonial; applicability of Law of Marriage Act and Land Act. Evidence – burden of proof – he who alleges must prove; oral evidence requires corroboration for matrimonial status. Mortgage Financing – compliance with Land (Mortgage Financing) Regulations and use of affidavit/declaration to establish sole ownership. Relief – validity of mortgage and auction where no proven spouse interest.
23 March 2020
Whether administrative correspondence to the Registrar suffices as sufficient cause to extend time to restore a dismissed application.
Extension of time – application to set aside dismissal for want of prosecution – sufficiency of reasons – affidavit must state reasons for delay – administrative correspondence to Registrar not proper remedy – Order IX and Order XLIII CPC; Law of Limitation Act s.14(1).
23 March 2020
Applicant's illness and counsel fee dispute did not justify extension of time to file notice and leave to appeal.
Civil procedure – Extension of time – Application for leave to appeal out of time – Sufficient cause required – illness and disputes with counsel insufficient where applicant fails to account for delay and lacks diligence; request by advocate for copies of ruling undermines excuse.
23 March 2020
An unregistered agreement purporting to transfer interest in registered land cannot support specific performance without proof of title.
Land law – registered land – instruments affecting title must be registered; unregistered agreements affecting registered land inadmissible to confer title. Evidence – necessity of producing certificate of title or search report when claiming rights in registered land. Specific performance – cannot be granted where the purported transfer instrument is unregistered and title is unestablished. Procedure – expungement of documents and striking out for failure to disclose cause of action.
23 March 2020
Applicant granted leave to seek extension of time due to delayed supply of judgment and prompt action after a struck-out application.
Civil procedure – extension of time – application under section 41(2) Land Disputes Courts Act – delay due to late supply of judgment and striking out of earlier application for wrong provision – discretion exercised in interests of justice.
23 March 2020
Appellant lacked locus standi to sue as administrator without letters; tribunal's dismissal substituted with striking out and appeal dismissed.
Civil procedure – locus standi – administrator of deceased estate – requirement to produce letters of administration; Appeals – maintainability – aggrieved party may appeal despite defective capacity at trial; Trial tribunals – power to raise locus standi suo motu; Appellate powers – substitution of orders under s.43(1)(b) Land Disputes Courts Act (Cap.216).
20 March 2020
An application for leave was incompetent where a certificate on points of law (not leave) was required; extraneous prayer struck out with costs.
Land law – Appeals – Distinction between first appeals and appeals on appeal – s.47(1) LCDA (leave) vs s.47(2) LCDA (certificate on points of law). Procedural law – Applicants must seek and support the precise relief in the chambers summons and affidavit; court will not convert applications by submissions. Civil procedure – Inadmissibility of extraneous prayers in submissions; such prayers are struck out with costs.
20 March 2020
An application to set aside a dismissal was dismissed as time‑barred for being filed after the statutory 30‑day limit.
Limitation law – setting aside dismissal order – item 4, Part III, Law of Limitation Act (30‑day limit); Civil Procedure – Order IX Rule 9(1) CPC – restoration of suit; Preliminary objection – time‑barred applications; Applicant’s failure to respond to court’s invitation – effect on jurisdiction.
18 March 2020
Application for extension of time dismissed as res judicata where same decision was already determined by the High Court.
Civil procedure – extension of time – res judicata – application seeking to appeal a tribunal decision already determined by the High Court in a prior appeal is incompetent; proper remedies are appeal to the Court of Appeal or application to set aside ex parte judgment.
17 March 2020
Purchaser who bought land in 2008 from compensated vendors failed to prove vendors had title; appeal dismissed with costs.
Land law – effect of government revocation and compensation on original owner’s title – sale by family after compensation – burden of proof on purchaser to show vendors had title to transfer – long undisturbed occupation as factor in competing land claims – appellate review of factual findings of tribunal.
16 March 2020
Whether listing a ward tribunal secretary on attendance list conclusively proves membership and mandates nullification of proceedings.
• Administrative law – tribunal procedure – whether listing a secretary on attendance list proves participation as a tribunal member – distinction from cases where secretary actively adjudicated. • Civil procedure – appellate review – nullification of lower tribunal proceedings suo motu for alleged irregular composition. • Overriding objective – limitations on curing substantive irregularities absent miscarriage of justice.
12 March 2020
Applicant's suit restored where medical report substantiated advocate's incapacity and personal attendance was not mandated.
Land law — dismissal for want of prosecution — restoration of proceedings — admissibility of medical report prepared after dismissal to prove advocate's earlier incapacity — reliance on advocate's appearance; Order III r.1; Order 9 r.8.
12 March 2020
Leave to appeal granted where arguable points of law include suo motu notice issues and relevance of sale agreements.
Land law – leave to appeal – Section 47(1) Land Disputes Courts Act – leave granted where prima facie point of law or mixed law and fact warrants Court of Appeal consideration; procedural fairness – raising issues suo motu and duty to give parties opportunity to be heard; relevance of sale agreements to land dispute.
11 March 2020
Appeal struck out for being incompetent where mandatory decree was not attached; late attachment by amendment did not cure defect.
Land law – appeals – procedural requirements for appeal from District Land and Housing Tribunal; limitation of time under s.41(2) Land Disputes Courts Act; mandatory attachment of decree and judgment under Order XXXIX Rule 1(1) Civil Procedure Code; limits of amendment to cure procedural incompetence.
11 March 2020
Trial tribunal erred by deciding a land dispute over a community water-well without visiting the locus in quo, judgment nullified.
Land law; locus in quo visits — not universally mandatory but necessary when factual issues (boundaries, community resource use) require on-site verification; evidence assessment — documentary versus oral; trial tribunal duty to inspect where community rights and boundary disputes affect reliefs.
10 March 2020
A later suit between successors in title was barred by res judicata; the prior ward tribunal decision prevails.
Civil procedure – res judicata – Section 9 Civil Procedure Code – subsequent suit between successors in title barred where matter was previously heard and finally decided. Land law – title succession – successors in title cannot relitigate ownership already determined by a competent tribunal. Appellate review – failure of trial and appellate tribunals to appreciate res judicata renders their proceedings null and void. Evidence – allocation receipts and witness contradictions were secondary where prior judgment on ownership remained unchallenged.
10 March 2020
Non-joinder of predecessors and survey companies rendered the land ownership judgment null; matter remitted for rehearing with necessary parties joined.
Land law; ownership disputes; identity and renumbering of surveyed plots; non-joinder of necessary parties (predecessors and survey companies); revisional powers; remittal for rehearing.
9 March 2020
Court grants extension to appeal where tribunal’s late supply of judgment impeded unrepresented applicant’s timely appeal.
Extension of time – sufficient cause – delay caused by late supply of judgment/decree by trial tribunal – unrepresented litigant’s need for copies – exercise of court’s discretion.
9 March 2020
A valid joinder by amendment and correctable clerical omission do not defeat res judicata; appeal dismissed.
Civil procedure – res judicata – section 9 CPC – requirements: same parties, same subject matter, same title, heard and finally decided by competent court. Joinder by amendment – a party validly joined by amendment is bound by subsequent judgment. Clerical omission – omission of a party's name on judgment is a clerical error correctable under section 96 CPC and does not vitiate res judicata. Preliminary objection – points of law (res judicata) do not require evaluation of evidence.
9 March 2020
Leave to appeal granted due to a jurisdictional dispute (probate versus land) and conflicting lower-court decisions.
Civil procedure – Leave to appeal under section 47(1) Land Disputes Courts Act – grant of leave where jurisdictional question and conflicting decisions exist. Jurisdiction – distinction between probate matters and land disputes; requirement to join administrator of estate. Appellate review – conflicting findings between tribunal and appellate court as a ground for leave to appeal.
9 March 2020
An incorrect statute revision year is curable, but an altered or defective jurat makes an affidavit incurably defective and application incompetent.
Civil procedure – Preliminary objection – Competence of application – Incorrect citation of revision year is a curable technicality under the overriding objective. Evidence/affidavit formalities – Jurat of attestation – Date in differing handwriting/ink and absence from served copy indicates possible alteration; affidavit incurably defective. Notaries Public and Commissioner for Oaths Act – Compliance with jurat requirements essential for affidavit validity.
9 March 2020
Applicants' delay to seek review was inordinate and unexplained; lack of funds and delayed counsel engagement did not justify extension.
Limitation of actions – extension of time under section 14(1) Law of Limitation Act – requirement to show sufficient cause; Delay – mobilization of funds and securing private legal representation do not automatically amount to sufficient cause; Procedural knowledge – presence of counsel at delivery of ruling negates claim of ignorance; Discretionary relief – unexplained inordinate delay disentitles applicant to extension.
9 March 2020
Extension of time granted because applicants were absent and not notified, permitting a review application to be filed within 15 days.
Civil Procedure – Extension of time – Section 14(1) Law of Limitation Act – whether absence and lack of notification amount to sufficient cause for enlargement of time; Natural justice – right to be heard – non-notification/absence as basis for review; Extension principles – requirement to account for delay and role of alleged illegality as factor in granting extension; Costs – costs to follow cause in intended application.
9 March 2020
Appellant failed to prove adverse possession; respondent’s inheritance evidence preferred and appeal dismissed with costs.
Land law – locus standi – party selection by applicant; Adverse possession – allocation and acquiescence required; Burden of proof – s.110 Evidence Act; evidential weight of testimony and village proceedings.
9 March 2020
Appellant lacked legal mandate to sue on deceased’s land; lower proceedings void and appeal dismissed with costs.
Property law – locus standi – suit over deceased’s property – requirement to produce Letters of Administration before suing on estate property; nullity ab initio. Civil procedure – jurisdiction – proceedings commenced by person without mandate are incompetent. Evidence – second appeal limited to misdirection on evidence; merits not considered where jurisdictional defect exists.
9 March 2020
Respondent’s seven-year undisturbed occupation constituted abandonment under s.45(1), defeating the applicant’s purchase claim.
Land law – Village Land Act s.45(1) – abandonment of customary land where not used for five years or more. Possession – undisturbed occupation for seven years constitutes abandonment and supports competing possession claims. Evidence – purchaser bears burden to rebut statutory abandonment where long adverse occupation is proved. Appeals – appellate tribunal’s factual findings on possession and abandonment will not be overturned absent misdirection.
9 March 2020
A consent judgment requiring withdrawal of proceedings rendered the subsequent land suit res judicata and ousted the court's jurisdiction.
Civil Procedure – res judicata (section 9 CPC) – requirement that matter directly and substantially in issue was previously heard and finally decided.* Consent judgments – settlement agreements adopted by court acquire contractual effect and bind parties; can oust jurisdiction by requiring withdrawal of pending suits.* Jurisdiction – consent order rendering court functus officio where parties agreed withdrawal of related proceedings.* Preliminary objections – pure points of law may be raised with leave and decided under Mukisa principles.
9 March 2020
Proceedings were void where respondent sued over deceased’s land before obtaining letters of administration.
Probate and administration – Letters of Administration obtained after suit commenced – locus standi to sue – timing of probate documents; jurisdiction of Ward Tribunal in matters involving estate administration; nullity ab initio where plaintiff lacks authority; appellate review for misdirection on jurisdictional facts.
9 March 2020
Registered title and letter of offer establish ownership; appellant failed to prove prior possession; damages reduced to TZS 3,000,000.
Land law – proof of ownership by Letter of Offer and Certificate of Title; challenge to title must be raised at trial; onus to prove prior possession; assessors’ opinion on record; appellate reduction of excessive general damages.
9 March 2020
A company must plead and show a board resolution authorising litigation; absence renders the suit incompetent and it is struck out.
Company law – separate legal personality; board of directors manage company affairs; resolution required to authorise litigation. Civil procedure – competence of suit; board resolution is a condition precedent and must be pleaded/annexed to the plaint. Preliminary objection – absence of board resolution may be decided on pleadings and renders suit incompetent.
6 March 2020
Appeal dismissed: appellant failed to prove ownership and respondent’s long peaceful possession established lawful ownership.
Land law – possession and ownership – prolonged peaceful occupation as basis for lawful ownership. Evidence – burden of proof – appellant challenging possession must prove ownership, cannot rely on defence weaknesses. Procedure – appellate submissions must adhere to grounds of appeal; new issues/annexures not in petition will not be considered.
6 March 2020
Customary land rights survive a governmental grant absent full compensation, so the appellant’s ownership claim failed.
Land law – ownership dispute over plot allocated by municipal council; customary/deemed right of occupancy – requirement of prompt/full compensation for displacement; allocation/grant does not extinguish customary title absent compensation; appellate review – adequacy of tribunal's analysis and non-joinder of land allocating authority.
6 March 2020
Defective affidavit paragraphs were expunged; nullified power of attorney does not bar challenging prior acts, and revision proceeds.
Civil procedure – Affidavits – Order XIX Rule 3(1) CPC – impermissible prayers in affidavit – expungement of defective paragraphs versus incurable defect; Locus standi – effect of subsequent nullification of special power of attorney on being sued for prior acts – revision proceedings admissible.
3 March 2020
Court granted extension to appeal despite advocate negligence, relying on alleged illegality and corporate reliance on officers.
Extension of time – sufficiency of cause – advocate’s negligence and lack of internal follow‑up – alleged illegality in impugned decision as ground for extension – corporate litigant’s reliance on officers – discretionary exercise of court’s power.
3 March 2020