R v Chibati Simati (Criminal Review Case 6 of 1941) [1941] ZMHCNR 10 (31 December 1941)

R v Chibati Simati (Criminal Review Case 6 of 1941) [1941] ZMHCNR 10 (31 December 1941)

Only one offence is committed under section 14(1)(a) of the Native Tax Ordinance for wilful default in paying tax, regardless of the number of years involved; therefore, only one count can be included in the charge.

Source-derived case information.

Citation
[1941] ZMHCNR 10
Parties
Prosecutor: Regina; Accused: Chibati Simati
Court
High Court of Northern Rhodesia
Jurisdiction
Zambia
Case Number
Criminal Review Case 6 of 1941
Procedural Posture
Criminal Review / Judgment
Outcome
Convictions quashed, sentences set aside, substituted with one conviction and sentence.
Legal Topics
Wilful Default in Tax Payment, Native Tax Ordinance, Multiplicity of Charges
Source Language
en
Criminal Law Tax Law Wilful Default in Tax Payment Native Tax Ordinance Multiplicity of Charges

Source-derived case record

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Parties

Regina

Prosecutor

Chibati Simati

Accused

Procedural Posture

Criminal Review / Judgment

  1. 1 Whether wilful default in paying tax for more than one year constitutes multiple offences under section 14(1)(a) of the Native Tax Ordinance

Ratio Decidendi

Only one offence is committed under section 14(1)(a) of the Native Tax Ordinance for wilful default in paying tax, regardless of the number of years involved; therefore, only one count can be included in the charge.

Court Disposition

Convictions quashed, sentences set aside, substituted with one conviction and sentence.

Orders

  • Convictions on two counts quashed
  • Sentences set aside