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. 

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100 judgments
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Judgment date
November 2024
A tribunal that strikes out an incompetent suit lacks jurisdiction to decide ownership; its substantive declarations are set aside.
Land law – locus standi – only executor or administrator can sue in respect of causes of action surviving the deceased. Civil procedure – striking out for incompetence – tribunal loses jurisdiction to determine merits thereafter. Power of attorney – donor's personal appearance may render POA redundant but does not cure lack of administrator. Declarations made in incompetent proceedings are nullities and of no legal effect
29 November 2024
Failure to serve statutory 90‑day notice on Attorney General and Solicitor General renders suit incompetent; suit struck out with liberty to refile.
Government proceedings – section 6(2) Government Proceedings Act – mandatory 90‑day notice to relevant department and copies to Attorney General and Solicitor General; non‑compliance renders suit incompetent; misjoinder and overriding objective cannot cure statutory preconditions; remedy – strike out with liberty to refile subject to limitation; no order as to costs.
29 November 2024
Administratrix granted Mareva injunction pending expiry of 90‑day notice to protect estate land from irreparable interference.
Mareva injunction – requirements where government is party – intention to sue and service of 90‑day notice. Interim relief – preservation of status quo, prevention of irreparable loss, and balance of convenience Locus – administratrix of deceased estate entitled to seek injunctive relief. Discretionary relief – court to exercise injunctive power judiciously
29 November 2024
A final judgment on land ownership creates rights in rem and bars the plaintiff's subsequent suit as res judicata.
Land law – res judicata – section 9 Civil Procedure Code – prior final judgment on land ownership creates rights in rem binding all, barring subsequent suit; preliminary objection admissible where facts assumed true.
29 November 2024
Special damages must be strictly proved; unproven special damages and constructive notice defeated the respondent's breach claim.
Civil procedure – Land/lease disputes – burden and strict proof of special damages; speculative awards impermissible. Contract/land law – non-payment of rent may amount to constructive notice of termination and defeat later breach claim. Civil procedure – non-joinder – objections must be raised early; late objections deemed waived Formalities – mistaken description of signatory’s capacity in a lease may be a minor slip not invalidating the instrument
29 November 2024
Applicant failed to account for delay and alleged illegality was not pleaded or apparent, so extension of time denied.
Civil procedure – extension of time – applicant must account for each day of delay; affidavit must disclose reasons for delay. Civil procedure – supporting affidavit – issues relied upon must be pleaded in the affidavit, not only in submissions. Extension of time – illegality as sufficient cause – illegality must be apparent on the face of the record of the impugned decision. Locus standi – alleged lack of locus standi not sufficient for extension where not pleaded or apparent on the record
29 November 2024
29 November 2024
Court granted Mareva injunction to preserve disputed land pending expiry of the 90‑day notice to sue the government.
Mareva injunctions – requirements for granting against government claims; 90‑day notice to sue the Government; prima facie interest in land; balance of convenience and prevention of irreparable loss.
29 November 2024
Appeal dismissed: ownership action timely, no proven procedural irregularity or miscarriage of justice.
Land law — limitation period for land ownership (12 years) — ownership versus trespass; Procedural irregularity — representation by allegedly unqualified advocate — appellate restraint where issue not raised at trial; Appellate review — s.45 Land Disputes Courts Act — reversal only for errors causing miscarriage of justice; Evidence — adequacy of tribunal's evaluation and site visit for boundary description.
29 November 2024
Applicant failed to show sufficient cause or apparent illegality to justify extension to appeal an ex parte judgment.
Limitation of actions – extension of time under s.14 – requirement to show good cause and account for each day’s delay; illegality ground – must be apparent on face of record (Lyamuya) – procedural irregularity (non-service/non-notification) challenges the ex parte order and should be pursued by setting aside that order at the tribunal.
29 November 2024
Court granted extension to file review, finding delay technical from pursuing wrong forum; no costs.
Civil procedure – Extension of time – Technical delay caused by pursuing wrong forum – Delay not inordinate where subsequent application dismissed as res judicata; accounting for delay assessed in context.
29 November 2024
Inheritance evidence established ownership; tribunal had jurisdiction; appeal dismissed with costs.
Land law – ownership by inheritance; proof of root of title without registered certificate; District Land and Housing Tribunal jurisdiction over ownership and possession claims arising from inheritance; long-term occupation insufficient to confer ownership.
29 November 2024
High Court lacks jurisdiction over tax charge registration; claim also time‑barred, so application dismissed.
Tax law – tax enforcement charge under Tax Administration Act – jurisdiction of tax dispute settlement forums v High Court; Limitation – challenge to initial registration is time‑barred; continuing wrong principle inapplicable
29 November 2024
A prior final judgment on the same plots barred the later application; execution delay did not defeat res judicata.
Res judicata – constructive res judicata – preclusive effect of final judgment between same parties/privities on same subject matter; Execution of decree – limitation (12 years) applies to enforcement proceedings, not to res judicata preliminary objections; Rectification of land register – administrative process under section 99(1) Land Registration Act, no express limitation; Change of administrator – does not avoid prior judgment's effect; Finality of litigation – courts must prevent multiplicity of suits.
29 November 2024
Appellate court set aside tribunal judgment, declared appellants owners, voided uncorroborated village land sale and restrained respondents.
Land law – village land sale formalities and corroboration; appellate re-evaluation of conflicting evidence; jurisdictional limits where land disputes implicate matrimonial issues; assessors' opinions – requirement to consider and give reasons for departure.
29 November 2024
A pending notice of appeal does not oust a tribunal's jurisdiction to tax costs; the applicant's challenge was dismissed.
Taxation — jurisdiction to tax costs — effect of pending notice of appeal; Preliminary objection — whether addressed by Tribunal; Court records — presumption of accuracy and requirement of compelling evidence to impeach; Stay of proceedings — necessity to apply for stay if prosecution of appeal is to suspend taxation; Execution separate from taxation — taxation does not automatically effect enforcement of costs.
29 November 2024
Court granted extension to file revision where tribunal allegedly decided ownership without hearing and illegality was apparent.
Land law – extension of time to file revision – illegality on the face of the record – right to be heard – lack of knowledge of judgment – authorities: VIP Engineering (illegality as sufficient cause).
29 November 2024
Tribunal’s dismissal upheld but respondent’s ownership declaration quashed; presumption of owner’s death raises risk of ownerless property.
Land dispute — ownership — failure to tender pleaded documents and summon material witnesses — adverse inference; Probate/matrimonial overlap — presumption of death after five years (s161 Law of Marriage Act; s117 Evidence Act) — risk property becoming ownerless; Tribunal’s competence to determine ownership challenged but declaration of ownership quashed; appeal dismissed.
29 November 2024
A suit dismissed for want of prosecution cannot be refiled; the correct remedy is to apply to set aside the dismissal.
Civil procedure – res judicata – effect of earlier dismissal for want of prosecution – subsequent refiling constitutes constructive res judicata. Civil procedure – remedies – dismissal for want of prosecution – proper remedy is an application to set aside the dismissal, then appeal if refused Land Disputes Courts Regulations (2003) – Regs 11 and 15 – procedure on non-appearance and dismissal for want of prosecution
29 November 2024
A plaint must state when the cause of action arose; omission renders the suit incompetent and it is struck out with costs.
Civil Procedure – Pleadings – Order VII r.1(e): a plaint must state the facts constituting the cause of action and when it arose; annexures cannot substitute for missing particulars; failure renders suit incompetent and liable to be struck out.
28 November 2024
A plaint must state when the cause of action arose; failure renders the suit incompetent and subject to being struck out with costs.
Civil procedure — Pleading requirements — Order VII r.1(e) — Plaintiff must plead facts constituting cause of action and when it arose; annexures cannot cure omission — Failure to state when cause of action arose renders plaint incompetent and suit liable to be struck out.
28 November 2024
28 November 2024
28 November 2024
A single title wrongly issued over two separately sold semi‑detached units is ineffectual; plaintiff owns one unit.
Land law – subdivision/semi‑detached units – error in issuing single title over two separately sold units; tenancy‑purchase transfers; proof of fraud in civil suits requires higher standard; declaration of ineffectual title; owner of unit entitled to declaration and costs.
28 November 2024
Court granted Mareva injunction where prima facie ownership dispute, risk of irreparable loss, and balance of convenience favored the applicant.
Land law — Mareva/freezing injunction — interim relief pending 90‑day statutory notice to sue Government; Atilio v Mbowe test: prima facie case, irreparable harm, balance of convenience; disputed title and alleged forged sale agreement.
28 November 2024
A special power of attorney limited to tribunal proceedings does not confer locus standi to sue in the High Court.
Land law – locus standi – special power of attorney limited to Land and Housing Tribunal proceedings does not confer authority to institute separate High Court suit; substantive nature of locus standi; overriding objective cannot cure substantive defects; name discrepancy in power of attorney raises doubt as to authorization.
28 November 2024
Failure to describe the suit land's size and boundaries renders the tribunal's proceedings and orders null and void.
Civil Procedure — Description of immovable property — Order VII Rule 3 CPC — Sufficiency of size and boundaries in plaint; Land law — Executability of decrees; Jurisdictional nullity — Tribunal erred where property not identified; Revisionary powers — Section 43 Land Disputes Courts Act (Cap 216 R.E.2019).
28 November 2024
Executing tribunal exceeded its jurisdiction by making new orders and appointing a broker; those orders were set aside.
Execution of decree – limits of executing court – executing court cannot add or vary decree – appointment of court broker/valuer – unlawful attachment and sale of judgment debtor's property where not decreed – remedy: set aside and remit execution to different chairperson.
28 November 2024
A Written Statement of Defence verified by someone other than the defendant breaches Order VI Rule 15 and may be struck out with costs.
Civil procedure – Pleadings – Verification of pleadings – Order VI Rule 15 Civil Procedure Code – Written Statement of Defence improperly verified by another person – Defective pleading – Strike out – Costs awarded.
27 November 2024
A written statement of defence improperly verified is defective and may be struck out with costs.
Civil Procedure — Written Statement of Defence — Verification — Order VI Rule 15 CPC — Defective pleading verified by improper person — Striking out — Costs.
27 November 2024
Extension of time granted to appeal an ex‑parte land judgment due to alleged illegality; preliminary objections dismissed.
Land law – extension of time to appeal – s.41(1) LDCA – ex‑parte judgments – right to appeal under s.70(2) CPC – illegality as sufficient cause for extension – res judicata and functus officio – preliminary objections on affidavit veracity require evidence.
26 November 2024
Appeal partly allowed: sale of one mortgaged property upheld; tribunal wrongly nullified the other auction on flawed grounds.
Contract law – mortgage sale conditions – extent of "involvement" by bank officer and constructive notice; Land law – recovery by sale of mortgaged property – statutory notice and public auction publication; Evidence – reliance on outdated valuation reports for pricing determinations; Statutory protection – purchaser protection under section 135(3) of the Land Act; Civil procedure – counterclaim dismissal; appellate review of Tribunal findings.
26 November 2024
Extension of time to appeal refused where Court of Appeal’s stay and concurrent proceedings made the application an abuse of process.
Land law – extension of time to appeal under s.41(1),(2) Land Disputes Courts Act; requirements for sufficient cause and accounting for delay; effect of Court of Appeal stay on subsequent extension application; abuse of process and forum shopping.
26 November 2024
Contradictory affidavit allegations defeated extension of time; taxing officer's decision upheld.
Advocates Remuneration Order — extension of time; service of written submissions — whether non-service amounts to illegality; affidavits tainted with falsehoods — cannot support relief; credibility and consistency of sworn statements.
26 November 2024
Court granted temporary injunction restraining respondents from auctioning disputed residential property pending main suit determination.
Civil procedure – Temporary injunction – Application of Atilio v. Mbowe three-fold test (prima facie case, irreparable loss, balance of convenience) – Restraint on auctioning disputed residential property pending determination of main suit Contract/default – Alleged contractual right to sell on default – Whether such issue should be determined at interlocutory stage or in main suit
26 November 2024
Application to extend time to set aside ex‑parte order struck out for omitting co‑defendants and misjoinder.
Land procedure – Application to extend time to set aside ex‑parte order – Misjoinder and omission of co‑defendants – Parties in subsequent proceedings must mirror original proceedings unless properly changed – Court may strike out incompetent application and may raise misjoinder suo motu.
26 November 2024
Failure to state the plaint’s subject-matter value (Order VII r.1(i)) renders the suit incompetent and it is struck out.
Civil procedure — Pleadings — Order VII Rule 1(i) CPC — Requirement to state value of subject matter for jurisdiction and court fees — Failure to state value renders plaint incompetent; Government party does not excuse requirement.
26 November 2024
A judgment deciding a limitation point suo motu without hearing parties is a nullity and must be quashed.
Civil procedure – right to be heard (audi alteram partem) – tribunal raising limitation suo motu in judgment without calling parties to address – decision without hearing is a nullity – quash and remit for rehearing.
26 November 2024
25 November 2024
Appeals against execution orders are incompetent; revision is the appropriate remedy for execution-related grievances.
Land Law - Appeal against execution order - Procedural irregularities in execution - Revision preferred over appeal.
25 November 2024
Suit dismissed as res judicata and for failure to serve mandatory 90‑day statutory notice to a government defendant.
Civil procedure – res judicata (Section 9 CPC) – dismissal for non‑appearance acting as final determination unless set aside; technical res judicata; Government Proceedings Act s.6(2) – mandatory 90‑day statutory notice to public authorities; proof of service as condition precedent to competent suit.
25 November 2024
The applicant's failure to aver service of mandatory 90‑day government notice renders the suit incompetent.
Government Proceedings Act s.6(2) – mandatory 90‑day pre‑action notice to Attorney‑General and government entity – must be expressly averred in the plaint Pleading requirements – annexures cannot substitute for a clear averment of statutory compliance Land Registration Act s.102 – 30‑day notice to Registrar applies only where there is a written decision, order or act by the Registrar Jurisdiction – absence of a specific statute ousting jurisdiction means the High Court may entertain reliefs even if administrative in nature
25 November 2024
A lawful settlement lodged in court is recorded as a consent judgment, binding the applicant and respondent to its terms.
Civil procedure – Consent judgment – Recording and incorporation of deed of settlement under Order XXIII r.3 CPC Settlement – Effect and binding nature of recorded Deed of Settlement – bars subsequent suits arising from same cause of action. Contractual terms recorded – rent payment obligation, conditional purchase option, termination on non‑payment, vacatur obligation Costs – each party to bear its own costs
25 November 2024
High Court set aside tribunal’s plot‑exchange remedy, declared the appellant owner, ordered vacation, and increased damages to TZS 10,000,000.
Land law — certificate of title as prima facie evidence of ownership; jurisdictional limits of Land Disputes Courts — exchange of plots as remedy; civil procedure — competency of appeal where decree not annexed but available on record; abuse of process — concurrent bill of costs and appeal; tort — trespass and assessment of general damages.
25 November 2024
Consent judgment records plaintiff as rightful owner, orders transfer, partial land surrender and registration adjustments.
Land law – Ownership dispute over registered title – Consent judgment following mediation – Order for transfer of possession and registration adjustments. Survey and registration – Commissioner for Lands and Director of Mapping and Survey required to cooperate in surveying, boundary adjustment and re-registration Settlement – Plaintiff’s partial surrender of 74.13 sqm to another defendant; waiver of costs and recording of settlement in land records
25 November 2024
An advocate who attested an affidavit cannot thereafter represent that party in the same proceedings; application struck out.
Notaries Public and Commissioners for Oaths Act s.7 – advocate who attests affidavit barred from representing that party in same proceedings; attestation renders commissioner a potential witness; mandatory statutory bar not cured by overriding objective.
25 November 2024
Appeal dismissed; tribunal’s jurisdiction, ownership finding and decree upheld; administratrix’s claim sustained.
Land law – limitation period and accrual of cause of action for recovery of land; Evidence – proof of ownership, credibility and locus in quo inspection; Pleadings – sufficiency of property description; Locus standi – administrator’s capacity to sue; Decree – clarity and executability; Procedural irregularity – clerical error vs substantive defect.
25 November 2024
Appellate court set aside tribunal decision and remitted the matter for retrial to consider force majeure and re-evaluate evidence.
Land law – Contract frustration/force majeure – Government directive altering market conditions; Civil procedure – framing of issues and discretion to consider issues arising by implication; Evidence – requirement for tribunal to evaluate and analyze credibility and relevance; Remedy – setting aside defective judgment and ordering retrial.
25 November 2024
Extension of time denied where applicant failed to account for delay and show arguable illegality in impugned judgment.
Civil procedure – extension of time – application under AJA s.11(1) – whether technical delay and clerical error by Deputy Registrar justify enlargement of time. Withdrawal of appeal – effect of withdrawal without leave to re-file – applicability of Order XXIII Rule 1 CPC to Court of Appeal proceedings Law of Limitation – exclusion of time spent prosecuting other proceedings (s.21(2) LLA) – requirement to account for each day of delay. Requirement to show diligence and arguable illegality to obtain extension of time
25 November 2024
Interim injunction refused where applicant failed to prove irreparable, non‑compensable loss and cumulative Atilio requirements.
Injunctions – interlocutory relief – Atilio v Mbowe test (triable issue, irreparable loss, balance of convenience) – irreparable loss must be non-compensable by damages – proof of triable issue by affidavit under Order XXXVII r.1 – public road designation contested.
25 November 2024