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. 

166 judgments
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166 judgments
Citation
Judgment date
October 2022
Delay in obtaining certified judgment copies justified a 21‑day extension to file the appeal for the applicant.
Land law — extension of time to appeal — application under section 41(2) Land Disputes Courts Act; Limitation — computation of period — exclusion of time spent obtaining certified copies under section 19(2) Law of Limitation Act — exclusion not automatic; party must apply for extension of time.
31 October 2022
High Court lacked pecuniary jurisdiction where only the house value fell below statutory threshold; suit struck out.
Land jurisdiction – High Court (Land Division) – scope under section 37(1) – recovery/possession of immovable property exceeding statutory pecuniary threshold. Pecuniary jurisdiction – valuation excludes movables and chattels; only land and affixed structures count. Preliminary objections – proper determination of jurisdictional issues as points of law (Mukisa principle). Res judicata – raised but not decided after disposal on jurisdiction.
31 October 2022
An interested non-party may seek revision of a tribunal decision; courts will not entertain unpleaded preliminary legal points.
Land law – Revision under s.43(1)(a),(b) LDCA – Interested non-party may challenge tribunal proceedings by revision rather than appeal. Civil procedure – Preliminary objection – parties are bound by their pleadings; unpleaded points of law cannot be entertained as surprise. Tribunal practice – Distinction between set-aside applications and revision in relation to ex-parte/execution orders.
31 October 2022
Applicant's medical evidence failed to account for inordinate delay; extension of time to appeal was refused.
Civil procedure – Extension of time – Applicant must account for every day of delay – Sickness may justify extension if properly explained and evidenced – Inordinate delay and unexplained periods justify refusal to extend time (Bushiri principle).
31 October 2022
Failure to join the Attorney General in proceedings against a municipal defendant renders the Tribunal decision incompetent and is quashed.
Government Proceedings Act s.6(2) – Joinder of Attorney General as necessary party in suits against government institutions – Procedural amendment applies retrospectively where hearing not commenced – Non‑joinder renders proceedings incompetent and liable to be quashed.
31 October 2022
Failure to prove joint title; registered Certificate of Title upheld and tribunal’s decision affirmed.
Land law – proof of ownership – registered title as prima facie proof of ownership; absence of appellant’s name defeats claim of joint ownership. Evidence – admissibility and sufficiency of documentary and oral evidence in land disputes. Jurisdiction – matrimonial/dowry disputes are matters for matrimonial/probate fora, not the Land Tribunal. Procedure – assessors’ opinions must be considered; tribunal may depart if reasons given.
31 October 2022
The plaintiff’s separate suit attacking a sale in execution was unmaintainable; remedy lies under Order XXI r.88 and s.38 CPC.
Civil Procedure — execution of decree — challenge to sale in execution — remedy under Order XXI Rule 88(1) CPC to set aside sale for material irregularity or fraud; Section 38 CPC — executing court’s exclusive jurisdiction to determine execution issues; separate suit attacking execution sale unmaintainable.
31 October 2022
Revision dismissed: tribunal’s consent Deed of Settlement upheld and court records presumed accurate.
Land law; revision under s.43(1)(b) Land Disputes Courts Act; consent Deed of Settlement; presumption of accuracy of court records; forgery allegations require proper challenge (criminal or evidential proof); revision limited to errors apparent on face of record or injustice.
31 October 2022
Applicant's sickness and filing of a second leave application did not constitute sufficient cause for extension of time.
Extension of time – discretion and sufficient cause; sickness and medical evidence – adequacy to explain delay; "technical delay" vs negligence; counsel's conduct and failure to peruse file not excusing delay.
31 October 2022
Appellant not a necessary party where land was transferred and he testified as witness; appeal dismissed with costs.
Land law – joinder of necessary parties – necessary party test (direct legal interest and being bound by outcome) – material witness vs necessary party – appellate courts will not entertain new grounds raised for first time on second appeal.
31 October 2022
Appeal dismissed: respondent’s documentary village allocation and testimony proved ownership on the balance of probabilities.
Land law – proof of ownership – documentary evidence and village allocation; credibility and weight of competing exhibits; admissibility and challenge of documents; substitution of administrator after defendant's death; appellate deference to trial court’s credibility findings.
31 October 2022
Leave to appeal is not maintainable after dismissal for want of prosecution; the correct remedy is to apply to set aside the dismissal.
Civil procedure — Leave to appeal — Application for leave to appeal to Court of Appeal — Not maintainable where underlying appeal was dismissed for want of prosecution — Proper remedy is application to set aside dismissal order; Section 47(2) Land Disputes Courts Act and Order XLII Rule 2 CPC considered.
31 October 2022
Tribunal complied with Regulation 23; applicant was heard and execution order was properly made and completed.
Land law — Execution proceedings — Regulation 23 GN.174/2003 — 14-day compliance period — Right to be heard in execution proceedings — Revisionary powers under s.43(1)(b) Land Disputes Courts Act — Written statement of defence not required for execution.
31 October 2022
Application for extension to file leave to appeal struck out as premature because no notice of intention to appeal was filed.
Civil procedure – Appeals to Court of Appeal – Requirement that notice of intention to appeal be lodged before applying for leave to appeal (Court of Appeal Rules, Rules 45(a) and 46(1)); Extension of time – application for extension to apply for leave to appeal incompetent if no notice of intention to appeal filed; Premature applications – applicant should await outcome of application to extend time for filing notice of appeal; Relevant authority: DPP v A.M. Swai and High Court precedents.
31 October 2022
Applicant's unexplained five‑year delay and lack of diligence warranted refusal to grant extension of time to appeal.
Extension of time – discretionary remedy – applicant must provide sufficient reasons and account for all delay; delay must not be inordinate. Requirement of diligence – ignorance of a judgment is not a sufficient excuse where record shows presence at delivery of ruling. Application for extension of time in land matters – principles in Mumello and Lyamuya applied.
31 October 2022
Extension of time to appeal granted where appellant obtained certified tribunal judgment and remained within statutory appeal period.
Civil procedure — Extension of time — Application under section 41(2) Land Disputes Courts Act and section 95 CPC — Judicial discretion and requirement of good cause. Limitation — Computation of appeal period — Section 19(2) Law of Limitation Act (exclude day of judgment and period to obtain copy). Delay attributed to tribunal's supply of certified judgment copy and personal/family difficulties — sufficiency of explanation.
31 October 2022
Applicant failed to establish Atilio v Mbowe requirements for interim injunction; application dismissed with costs.
Civil Procedure – Interim injunctions – Requirements in Atilio v Mbowe: serious question to be tried; risk of irreparable harm; balance of convenience – Order XXXVII Rule 1(a) CPC – necessity to prove likely damage or loss in affidavit.
31 October 2022
Applicant’s medical evidence failed to account for inordinate delay; extension of time to file review refused, no costs.
Extension of time – applicant must account for all delay – medical evidence insufficient to explain delay – inordinate delay – reliance on Mumello and Lyamuya guidelines – unproven execution claims inadmissible where not deponed to in affidavit.
31 October 2022
Appeal dismissed; trial tribunal's admission of exhibits, findings on capacity, ownership and damages upheld.
Land law – admissibility of exhibits and annexures; capacity to contract – minority and burden of proof; admissibility of land offer letters and registration; estoppel and proper party to sue; assessment of general damages; sufficiency of tribunal's reasons.
29 October 2022
29 October 2022
Delay awaiting tribunal decision copy excluded; extension to appeal granted, appeal to be filed within 21 days.
Land law – Extension of time to appeal under s.41(2) Land Disputes Courts Act; exclusion of delay while awaiting judgment copy under s.19(2) Law of Limitation Act; requirements for good cause (Lyamuya factors); allegation of illegality on face of record.
28 October 2022
An appeal filed beyond the 45‑day statutory period is time‑barred; online submission is incomplete until formally admitted.
Appeals — Limitation — Section 41(1),(2) Land and Disputes Courts Act — 45-day appeal period; Electronic filing — submission incomplete until admission, control number and payment; Correction of mis-cited statute — permissible where respondent can respond; Overriding objective and court vacation — cannot cure mandatory time-bar limits.
28 October 2022
Sale under a decretal settlement must be challenged in the executing court under Section 38 and O.XXI r.88.
Civil Procedure — Section 38 CPC — exclusive jurisdiction of executing court over execution, discharge and satisfaction of decrees; Order XXI r.88(1) CPC — remedy to set aside sale in execution for material irregularity or fraud; settlement deed adopted as decree; improper separate suit; suit struck out.
28 October 2022
The applicant must exhaust statutory execution methods before seeking arrest and detention of the judgment debtor.
Execution — civil imprisonment — application premature where other statutory modes of execution (delivery, attachment and sale) not exhausted; discretionary nature of detention; section 42, Civil Procedure Code; Order XXI execution rules.
28 October 2022
An ex parte tribunal decision must first be challenged by setting aside the order at the tribunal before seeking revision in High Court.
Civil procedure – Extension of time under Law of Limitations Act, s.14(1); Ex parte judgments – appropriate remedy is application to originating tribunal to set aside ex parte order before pursuing revision; Competence of forum – High Court may decline extension for revision if tribunal remedy remains available.
28 October 2022
Court ordered respondents to produce transfer-related documents under oath due to contradictory denials and lack of proof.
Discovery – Order XI Rules 10 & 12 CPC; production of documents relating to land sale and transfer; facilitator's custody and knowledge of documents; contradictions in counter-affidavits; failure to prove lawful non-possession or seizure; court-ordered discovery before trial; costs awarded to applicant.
28 October 2022
Applicant’s unexplained, inordinate delay and insufficient reasons warranted dismissal of the extension of time application.
Civil procedure – extension of time – discretion to grant – applicant must show sufficient cause and account for each day of delay. Court of Appeal Rules, Rule 83(5) – Notice of Appeal does not require attachment of the judgment. Illegality – must be apparent on the face of the record to justify extension of time. Procedural objections – objections raised late in submissions without justification may be disregarded.
28 October 2022
The applicant failed to prove customary ownership; the respondent's sale agreement and municipal records established superior title.
Land law – ownership – proof of title – documentary evidence and registration outweigh uncorroborated customary occupation. Burden of proof – he who alleges ownership must prove it; oral evidence unsupported by documents is insufficient. Admissibility and evidential weight of sale agreements, municipal verification forms, survey records, and payments towards certificate of title. Reliefs – claim for declaration, damages and eviction dismissed where applicant fails to prove ownership.
28 October 2022
Purchaser at a lawful bank auction acquires title under power of sale and can recover damages for denial of possession.
Land law – auction sale under power of sale – transfer of ownership and protection of a bona fide purchaser under the Land Act (ss.133,135). Civil procedure – counterclaim – ex parte proceedings where service admitted and no reply filed (Order VIII r.14 CPC). Damages – specific (special) damages must be pleaded and strictly proved; unproven periods not awarded. Reliefs – declaration of ownership, eviction order, permanent injunction, specific and general damages, costs.
28 October 2022
Applicant failed to show sufficient cause to set aside abatement for not substituting a legal representative within 90 days.
Civil procedure – Abatement and restoration – Order XXII Rules 3 & 9 CPC – Substitution of legal representative within 90 days – Time runs from death – Formal probate not prerequisite – Failure to show sufficient cause warrants dismissal.
28 October 2022
Leave to appeal granted because applicant’s grounds disclosed an arguable appeal on burden, evidence evaluation and reliefs.
Civil procedure – leave to appeal – discretionary power of High Court – focus on whether intended appeal raises arguable issues, questions of general importance or novel points of law; Evidence – allegations of shifting burden of proof and failure to re-evaluate evidence as grounds for arguable appeal; Reliefs – challenge to determination of reliefs may warrant appellate intervention; Relevant law: Land Disputes Courts Act s.47, Appellate Jurisdiction Act s.5(1)(c), Court of Appeal Rules Rule 45(a), Civil Procedure Code s.95.
27 October 2022
Plaintiff’s suit dismissed for failure to comply with court orders after procedural non‑compliance by parties.
Civil procedure – preliminary objections – failure to file ordered written submissions – dismissal for want of prosecution; procedural compliance – parties’ failure to address competence – dismissal of suit; court orders – binding nature and consequences of non‑compliance.
27 October 2022
Applicant failed to satisfy Atilio criteria for an interim injunction; application dismissed with costs.
Civil Procedure – Interim injunction – Application under Order XXXVII Rule 1(a) and sections 68(c), 95 CPC – Applicant must satisfy Atilio v Mbowe three‑part test (serious triable issue, irreparable injury, balance of convenience). Parties – Proper parties and locus standi – court considered whether application was brought against correct parties. Evidence – Allegations of confiscation/demolition insufficiently linked to respondents; denial of involvement undermined grant of interlocutory relief.
27 October 2022
Change of chairperson without recorded reasons and unsigned witness evidence render tribunal proceedings null; retrial ordered.
Land law — Procedural irregularities in tribunal proceedings — Succession of chairpersons without reasons — Jurisdiction and nullity; Assessors’ questions — proper stage; Mandatory signing of witness evidence — authentication and incurable irregularity; Revisionary powers — order for retrial de novo.
27 October 2022
Court overruled preliminary objections on limitation, cause of action, and compensation for lack of proof.
Land law – limitation period – accrual of cause of action – limitation runs from date of disposition of land; inability to prove disposition date defeats time-bar objection. Civil procedure – cause of action – sufficiency of plaint; allegations of non-citizenship unproven and do not defeat plaint at preliminary stage. Procedural remedy – dispute over unpaid compensation is a factual matter for trial or counterclaim, not a preliminary objection.
27 October 2022
Application to restore dismissed land appeal denied for failure to show sufficient cause; advocate's negligence imputed to applicant.
Civil Procedure — Order IX Rule 6(1) — Setting aside dismissal for non-appearance — "Sufficient cause" required. Evidence — Adequacy of proof for claimed reasons (bus tickets insufficient to prove funeral attendance). Legal representation — Negligence of advocate imputable to client; client cannot benefit from advocate's default (Kepha Huzi precedent). Restoration of proceedings — applicant must show satisfactory cause to warrant restoration.
27 October 2022
Leave to appeal granted where grounds raised prima facie arguable points on land ownership, survey nullification and burden of proof.
Land law – leave to appeal under s.47(2) Land Disputes Courts Act – discretionary grant where grounds disclose prima facie/arguable appeal; issues include ownership proof, nullification of survey versus resurvey, applicable burden of proof (ss.110/111 v s.119 Evidence Act), re-evaluation of evidence, and retrospectivity/applicability of planning/survey statutes.
26 October 2022
Leave to appeal refused where affidavit failed to disclose specific prima facie or arguable grounds.
Leave to Appeal – Requirements for grant of leave – need for prima facie/arguable grounds or novel point of law; supporting affidavit must specifically plead grounds; court will not accept new points raised only in oral submissions; mere assertion of illegality insufficient.
26 October 2022
Applicant's failure to prove marriage meant the mortgage's spousal-consent requirements were not displaced; appeal dismissed.
Land law – Mortgage validity – requirement of spousal consent for matrimonial home under the Land Act; proof of marriage under the Law of Marriage Act (Section 55); Civil procedure – jurisdictional limits of District Land and Housing Tribunal regarding matrimonial disputes; Evidence – burden to prove marital status by admissible documents, not mere occupation.
26 October 2022
Appellant failed to overturn tribunal’s finding that respondent proved land ownership by admissible documentary evidence.
Land law – proof of title – burden of proof on balance of probabilities; documentary evidence admitted without objection carries significant weight. Evidence – credibility and weight – court may distrust documents that appear anachronistic or computer‑generated for an earlier era. Procedure – substitution/joinder of administrator where defendant dies during proceedings; no need to reopen where administrator steps in and files requisite form. Civil practice – failure to challenge exhibits or cross‑examine on key inconsistencies can render such objections an afterthought.
26 October 2022
Advocate’s sickness may justify restoring a dismissed matter, but repeated non-appearance and lack of explanation warrant dismissal with costs.
Land procedure – setting aside dismissal for want of prosecution – advocate’s sickness as ground – need for adequate explanation and supporting affidavit – cumulative non-appearance justifying dismissal – duty to notify court or appear personally.
26 October 2022
Applicant's delay in filing an appeal was not excused; alleged illegalities were not apparent on the face of the record.
Land — Extension of time to appeal — requirement to show sufficient cause; applicant must account for each day of delay; alleged illegality must be apparent on face of record (Lyamuya principle); financial hardship requires credible, specific proof.
26 October 2022
Medical evidence was insufficient to show good cause to set aside the ex-parte judgment; application dismissed with costs.
Civil procedure – setting aside ex-parte judgment – requirement to show 'good cause' under s.95 and Order VIII r.15(1) CPC – medical evidence as proof of sickness – sufficiency and timing of medical chits – prior extension of time and failure to comply – irrelevance of property transfer to setting aside application.
26 October 2022
Res judicata and functus officio objections overruled where prior proceedings did not decide the same land dispute and reliefs.
Land law — res judicata (s.9 CPC) — identity of subject matter — requirement that matter be directly and substantially in issue in former suit — functus officio — preliminary objections and need for evidence to establish identity of land and reliefs.
26 October 2022
Subsequent suit challenging the same mortgage was barred as abuse of process/res judicata; suit struck out with costs.
Land law – res judicata/abuse of process – functus officio where prior dismissal finally disposed of same subject matter; Civil procedure – preliminary objections on limitation and Order IX compliance; Reliefs/substance over form in determining same cause of action.
26 October 2022
First objection (time bar) overruled; second objection (amendment beyond court order) sustained — plaintiffs changed parties without leave.
Land law — preliminary objections — limitation: compensation under Item 1 of the Law of Limitation Act — private promise vs. claims "in pursuance of any written law"; Civil procedure — amendment of pleadings — compliance with court orders — adding/removing parties requires leave of court; non‑compliance may amount to contempt.
25 October 2022
Amending a plaint beyond a court’s leave by changing parties justifies striking out the suit; limitation objection was dismissed.
Civil procedure – preliminary objections – limitation of actions – distinction between compensation pursuant to written law and private commitments under Limitation Act. Civil procedure – amendment of pleadings – parties – requirement to seek leave before changing parties – compliance with specific court orders. Failure to comply with court orders may result in striking out of suit and costs.
25 October 2022
Failure to attach lower tribunal proceedings does not invalidate a High Court revision application under the Land Disputes Courts Act.
Land law – Revision – Whether attachment of lower tribunal proceedings is required in High Court revision applications – Sections 41(1) and 43(1)(a),(b) Land Disputes Courts Act – Distinction between Court of Appeal and High Court practice.
25 October 2022
Applicant's request for extension was dismissed; delay blamed on applicant's negligence and alleged illegality was not facially apparent.
Civil procedure – Extension of time – whether delay in supply of certified copies by trial tribunal constitutes sufficient cause; burden to show timely follow-ups and explain days of delay. Appeal – grounds of illegality – illegality must be apparent on the face of the record to support extension of time. Evidence – applicant must account for all periods of delay and provide concrete proof of attempts to obtain records.
25 October 2022
Extension refused: delay not accounted and alleged illegality not apparent on the record.
Land law – Extension of time to appeal under section 41(2) Land Disputes Courts Act; requirements for good cause (promptness, explanation, diligence, accounting for delay); illegality as ground for extension only if apparent on face of record; alleged matrimonial property sale not an apparent illegality; ignorance of law or lack of legal representation not a sufficient ground.
25 October 2022