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. 

68 judgments
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68 judgments
Citation
Judgment date
February 2025
Application seeking to halt execution and invoke Section 38(1)/O.XXI r.57 was not maintainable and was struck out without costs.
Civil Procedure – Section 38(1) & Order XXI r.57 – appropriateness of remedy; Execution proceedings – attachment/sale of land; Res judicata/finality – prior judgment binding; Abuse of process – relitigation; Withdrawal of application – court’s discretion as to costs.
28 February 2025
Non-joinder of land authorities in a land-title dispute rendered DLHT proceedings a nullity; parties must refile in High Court joined with necessary authorities.
Land law – Registered land and competing titles – Non‑joinder of Registrar of Titles, municipal authority and Commissioner for Lands – Miscarriage of justice; Civil procedure – Necessary parties and joinder – failure to join land authorities renders proceedings a nullity; Land Disputes Courts Act s.43(1)(b) – nullification of DLHT proceedings.
28 February 2025
A prior dismissal of identical claims renders the court functus officio and bars re-litigation of the same cause of action.
Civil procedure – preliminary objections; functus officio – effect of prior dismissal; distinction between strike out and dismissal; res judicata; judicial notice of prior proceedings.
28 February 2025
A chamber summons with incompatible, non-interrelated prayers is an omnibus application and may be struck out.
Civil procedure – chamber summons – omnibus application – whether multiple prayers in one summons render it defective; Order XLIII/Order XXXVII principles – combination of interrelated prayers permissible; incompatible or discordant prayers render application incompetent; Reliefs for contempt — inconsistent remedies (committal vs alternative fine) may create incompatibility in prayers.
28 February 2025
An application to review a taxing master's decision is incompetent if it joins new parties not involved in the original proceedings.
Civil procedure – party identity – incompetence of application when new parties are joined at reference stage – striking out for procedural irregularity.
28 February 2025
Court records and enforces parties’ Deed of Settlement as a consent judgment, making its payment, release and release-of-claims terms binding.
Civil procedure – Consent judgment – Recording of Deed of Settlement under Order XXIII r.3; Settlement terms enforced as court order; Release of title and vehicle documents; Discharge of encumbrances; Right to sell on default; Full release of civil and criminal claims; Settlement effective from date of lodgment and binds successors.
28 February 2025
Unopposed application for temporary injunction granted to preserve status quo and restrain construction pending main suit.
Land law – interim relief – temporary injunction under Order XXXVII of the Civil Procedure Code to preserve status quo pending main suit Injunctions – purpose to prevent irreparable harm and maintain subject matter of litigation Procedure – unopposed application: court may grant injunction without extended examination of authorities where respondent does not object Evidence – affidavit and annexures alleging ongoing construction relied upon in absence of counter-affidavit
28 February 2025
Failure to join the Registrar of Titles and Attorney General rendered the land suit incompetent and liable to be struck out with costs.
Land law – necessary parties – Registrar of Titles must be joined where title documents and ownership are in dispute Government Proceedings Act s.6(3) – Attorney General to be joined where government or its officers are affected by reliefs sought. Civil procedure – incompetence – failure to join necessary parties warrants striking out Costs – costs follow the event; repeated procedural failures justify awarding costs to defendants
28 February 2025
A trespass suit is barred by res judicata where an earlier final judgment declared the defendant owner of the same property.
Res judicata – section 9 Civil Procedure Code – identity of parties and subject matter – capacity of party immaterial – prior ownership decree bars subsequent trespass claim; competency of suit; Annexure P1 judicial notice.
28 February 2025
The plaintiff’s suit was dismissed as res judicata; failure to reply conceded the defendants’ preliminary objection.
Civil procedure – Res judicata – Suit dismissed where former suit between same parties on same subject matter was finally determined; Section 9 Civil Procedure Code applies. Procedural law – Failure to file reply to submissions deemed concession – uncontroverted preliminary objection. Abuse of process – Relitigation instead of appeal or review impermissible
28 February 2025
Defendant breached sale agreement; Plaintiff entitled to refund of TZS 50,000,000 with interest; bank exonerated.
Sale of encumbered land interest—breach for failure to deliver title document; claimant’s abandonment of specific performance—court retains jurisdiction to order refund of part-payment; insufficiency of evidence for general damages; third party (mortgagee) not liable where decree execution procedures and appellate stay pending.
28 February 2025
Mareva injunction application struck out as redundant after the 90-day notice-to-sue period lapsed; each party bears own costs.
Civil procedure – Mareva injunction – interim ancillary remedy – effect of lapse of 90-day period after notice of intention to sue rendering injunction redundant. Civil procedure – striking out application overtaken by events Costs – overriding objective – discretionary refusal to award costs; each party to bear own costs
28 February 2025
Applicants granted interim injunction after showing prima facie case, irreparable loss (loss of home) and favorable balance of convenience.
Civil procedure – interim injunctions – Atilio v Mbowe test (prima facie case, irreparable loss, balance of convenience); disputed mortgage validity and absence of notice of sale; preservation of status quo pending Land Case No. 2969 of 2025.
28 February 2025
An application to be added in a land suit was dismissed for want of prosecution after applicants failed to file ordered submissions.
Civil procedure – application to be added in pending suit under Order I Rule 3 and s.95 CPC – obligation to comply with court directions – failure to file ordered written submissions – dismissal for want of prosecution.
28 February 2025
28 February 2025
28 February 2025
An administrative listing of heirs in a purchase form does not confer the applicant inheritance rights; probate court decides heirship.
Property law – ownership dispute – burden of proof for monetary contributions to purchase – documentary evidence required. Succession law – effect of naming "heirs" in administrative purchase/registration forms – no automatic succession rights. Testamentary formalities – mere mention of names in a contract is not a valid will Jurisdiction – heirship and succession issues fall within probate jurisdiction; land courts should not determine probate matters. Title and contractual documents – sale agreement and certificate of title prima facie evidence of ownership
28 February 2025
Unchallenged Ward Tribunal decision and subsequent survey established respondent’s title; appellant’s appeal dismissed.
Land law – ownership and transfer – effect of unchallenged Ward Tribunal decision on title; Sale agreements – validity and clerical errors; Evidence – survey plan confirmation of title; Procedure – locus in quo visit not mandatory; First appeal – rehearing and re-appraisal of evidence.
28 February 2025
Court granted interim injunction restraining rival claimant and land authorities from disposing or registering transactions pending trial.
Land law – Interim injunction – Attilio v Mbowe test – prima facie case, irreparable harm, balance of convenience – rival claims to registered title – restraint on disposal and on land authorities from registering transactions pending determination of ownership.
27 February 2025
An application for extension of time to appeal previously decided by the same court is barred by res judicata and functus officio.
Civil procedure – res judicata – section 9 CPC – multiplicity of suits and finality of litigation. Civil procedure – functus officio – when a court has finally determined an issue it cannot re-entertain it Procedure – extension of time to appeal – prior determination bars relitigation even if new jurisdictional argument raised as afterthought. Abuse of process – misleading pleadings and tactical relitigation
27 February 2025
Court strikes out application for extension of time as res judicata and functus officio, reinforcing finality in litigation.
Civil Procedure - Res judicata - Functus officio - Application for extension of time - Jurisdiction issues.
27 February 2025
27 February 2025
An order made in execution proceedings is not appealable; the proper remedy is revision, so the appeal was struck out.
Civil procedure – execution proceedings – appealability of orders arising from execution – such orders are not appealable; revision is the proper remedy.
27 February 2025
27 February 2025
26 February 2025
A ward tribunal’s adjudicative mediation and non‑joinder of the owner/agent rendered DLHT proceedings premature; mediation quashed.
Land law – Civil procedure – Joinder of parties – Order 1 Rule 3 CPC – owner and agent as necessary/proper parties; Mediation – ward tribunal exceeded mediation role, breached confidentiality and made adjudicative findings; District Land and Housing Tribunal – proceedings prematurely preferred absent proper mediation certificate; Remedy – quash ward mediation, remit for fresh mediation; costs each party to bear own costs.
26 February 2025
Representative suit struck out for defective 90‑day notice and failure to publish court‑ordered advertisement.
Administrative law; Government Proceedings Act s.6 – mandatory 90‑days' notice to sue the Government; Civil Procedure Code Order 1 r.8(1) – representative suits and publication requirement; procedural competence – failure to include all claimants in statutory notice and failure to publish court‑ordered notice are fatal; striking out of incompetent suit.
26 February 2025
A plaintiff who withdraws a suit without leave is precluded from re‑filing the same claim under Order XXIII.
Civil procedure — Withdrawal of suit — Order XXIII r.1(2)(b) and r.1(3) CPC — Withdrawal without leave precludes re‑filing the same claim; failure to reply to pleaded fact amounts to concession.
25 February 2025
Plaintiff’s repeated abandonment and non-appearance warranted dismissal for want of prosecution with costs.
Civil procedure – Dismissal for want of prosecution – Order IX Rule 5, Civil Procedure Code Cap 33 RE 2019. Abuse of court process – repeated institution and abandonment of proceedings on same cause of action. Non‑appearance at pre‑trial conference as ground for dismissal and award of costs
25 February 2025
Uncertainty of service of hearing summons constituted sufficient cause to set aside dismissal and restore the suit.
Civil procedure — Setting aside dismissal for want of prosecution — Order IX Rule 6(1) CPC — Sufficiency of cause — Uncertainty/lack of proof of service of hearing summons and orders — Overriding objective and non‑fatal wrong citation of provision — Right to be heard.
24 February 2025
Whether the executing tribunal may alter a decree by ordering demolition and effect of a belated objection.
Land law – execution of decrees – executing tribunal must give effect only to terms of the decree and cannot add or vary reliefs. Civil procedure – execution – Regulation 23(4) & (5) GN No. 174 of 2003 – objection to execution must be before the executing court at time of hearing. Natural justice – right to be heard – no denial where objection was filed after determination of execution application
24 February 2025
Rectification of a registered land title without proper notice and hearing is invalid; owner’s name restored.
Land registration – Rectification of register under s.99(1)(f) – Procedural safeguards and notice under s.99(2)(c) – Right to be heard/natural justice – Alleged non‑compensation of prior customary owner – Administrative lapse cannot arbitrarily dispossess registered owner – Setting aside rectification and restoration of title.
24 February 2025
24 February 2025
Appeal against a District Land and Housing Tribunal execution order is incompetent; execution orders are not generally appealable.
Civil procedure – execution orders – appealability under section 74 Civil Procedure Code; remedy by review/revision. Land law – alleged disposition/alteration of registered land and involvement of Commissioner for Lands/Attorney General. Execution proceedings limited to enforcement; substantive issues and preliminary objections must be raised in main proceedings or by proper interlocutory application
24 February 2025
Court granted a seven-day extension to file an appeal under section 14(1), finding the applicant met the Lyamuya threshold.
Civil procedure – Extension of time – Application under section 14(1) Law of Limitation Act – judicial discretion and Lyamuya principles. Non-opposition/concession by respondents relevant to exercise of discretion. Timeline: applicant given seven days to file intended appeal
24 February 2025
Irregular site-visit and lack of proof of valid title vitiated the tribunal decision; appeal allowed and decision set aside.
Land law – locus in quo/site visit – procedural requirements (note-making, reading to parties, reconvening); Title – nemo dat quod non habet; Disposition of matrimonial property – necessity of spousal consent and documentation; Admissibility and weight of oral evidence; Failure to call material witness – adverse inference; Standard of proof – balance of probabilities.
24 February 2025
A Mareva injunction cannot be extended beyond the 90‑day statutory notice to cover a suit not yet instituted.
Civil procedure – Review for error apparent on the face of the record – Order XLII Rule 1 and section 95 CPC. Mareva injunction – temporal limits – injunction tied to expiry of 90‑day statutory notice cannot be extended pending determination of a suit not yet instituted. Right to be heard – absence of notice of hearing must be supported by record to succeed. Rectification of drawn order to remove illegal extension of injunction
21 February 2025
Failure to visit the locus in quo in an access/easement dispute warranted quashing and remand for a fresh on‑site assessment.
Land law — easement/access — locus in quo — discretionary but necessary visit where facts dictate — failure to visit may vitiate proceedings; quashing and remittal; assessors' participation.
20 February 2025
An appeal from a consent decree is barred by section 70(3) CPC; challenge requires a fresh suit, not execution proceedings.
Land law – Execution of consent decree – Section 70(3) Civil Procedure Code bars appeals from decrees passed by consent; executing court cannot set aside consent decrees; allegation of forged signature requires factual inquiry and cannot be resolved as a pure point of law.
20 February 2025
Applicant failed to show good cause for extension of time; inordinate unexplained delay led to dismissal with costs.
Civil procedure – Extension of time – section 14(1) Law of Limitation Act – requirement to account for each day of delay. Principles applied – Lyamuya Construction Co Ltd Bushiri Hassan – diligence, inordinate delay, and good cause. Correction of trial judgment/decree – failure to obtain timely corrections does not automatically excuse unexplained delay
20 February 2025
A suit re‑litigating rights determined by a prior decree is barred by res judicata and dismissed with costs.
Civil procedure – Res judicata – Section 9 CPC – applicability where prior settlement adopted as decree bars re-litigation. Same subject matter – loan facility and mortgaged property enforcement. Parties and privies – change of auction agent does not defeat res judicata Finality – settlement registered as decree conclusively determines rights; dismissal with costs
20 February 2025
A temporary injunction application was struck out after the underlying suit was dismissed as res judicata, with costs.
Land law – interlocutory relief – application for temporary injunction – competence of ancillary applications where underlying suit is dismissed as res judicata; preliminary objection – res judicata – determination of preliminary objection before ancillary matters; striking out incompetent applications and awarding costs.
20 February 2025
Appellant failed to prove exclusive ownership; hearsay evidence and document discrepancies justified upholding the Tribunal's decision.
Land law – proof of ownership – intention to gift property and exclusion from deceased’s estate – necessity of clear, direct and corroborative evidence Evidence – hearsay versus direct evidence – witnesses who only ‘traced’ or ‘saw’ documents insufficient to prove transactional facts. Documentary discrepancies – divergent names and inconsistent dates undermine credibility of title documents Procedure – tribunal raising issue of residential licence validity arising from cross-examination and submissions does not breach natural justice. Civil procedure – non-joinder of municipal authority and Attorney General not fatal where they are not necessary parties
20 February 2025
Adverse possession inapplicable where respondent claims purchase; appeal dismissed due to appellants' unpleaded, weak evidence.
Land law — proof of title and pleadings — need to plead description/size and facts relied upon; Tribunal judgments — regulation 20(1) GN.173/2003 requires brief facts, issues, findings and reasons but format flexible; Evidence — first appellate court may re‑evaluate evidence and exhibits; Adverse possession — doctrine inapplicable where ownership is claimed by purchase; Failure to prove title and reliance on unpleaded facts fatal to claim.
20 February 2025
An appeal is incompetent if brought against a respondent personally when they acted as estate administrator below.
Probate and Administration – capacity to sue – Section 71 of the Probate and Administration of Estates Act – locus standi – parties in original proceedings must appear in appeal – striking out appeal for wrong party cited.
20 February 2025
Unsworn testimony before the Land Tribunal nullifies proceedings from that date and mandates rehearing of that evidence.
Procedure – Evidence – Oaths and Statutory Declarations Act, Cap 34 – Every court (including District Land and Housing Tribunal) must administer oath or affirmation to witnesses Evidence – Unsworn testimony – Evidence given by witnesses not sworn or affirmed vitiates proceedings from the date such evidence was received Remedy – Quashing of proceedings and setting aside of subsequent orders and judgment; direction to receive afresh sworn/affirmed testimony
20 February 2025
Court allowed ex parte hearing of counterclaim where plaintiff failed to file defence and gave insufficient reasons for delay.
Civil procedure — Counterclaim — Failure to file defence within prescribed time under Order VIII Rule 11 CPC — Extension of time — Overriding objective/oxygen principle cannot displace mandatory procedural provisions — Ex parte hearing under Order VIII Rule 14(1) CPC.
20 February 2025
A counterclaim must expressly plead the value of the subject matter to confer High Court pecuniary jurisdiction.
Civil procedure – Counterclaim treated as plaint (Order VIII r9(2)) – Pleading requirement to state value of subject matter for jurisdiction (Order VII r1(i)) – Pecuniary thresholds under Land Disputes Act s37 – Preliminary objection procedure – Advocates Act s39 on documents prepared by unqualified persons (procedural notice requirement).
19 February 2025
Counterclaim struck out for lacking a statement of value needed to establish jurisdiction.
Civil procedure - counterclaim - jurisdiction - value of subject matter -pecuniary jurisdiction
19 February 2025
Court stayed proceedings and referred the dispute to arbitration under a valid contractual arbitration clause, granting a six-month stay.
Arbitration – contractual arbitration clause – referral and stay under Arbitration Act 2020 (ss.12–14) – court to refer unless prima facie arbitration agreement invalid. Existence of arbitration clause does not oust court jurisdiction; court may stay proceedings. Application for stay permissible notwithstanding other contractual dispute-resolution steps not yet exhausted. Sanctity of contract and party autonomy to choose arbitration
19 February 2025