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MAVIS FIAGBOR V. MAERSK LINE TEMA

Case

Jurisdiction

High Court

Judge

N/A

Catalog Type

Case

Judgement Date

Oct 25, 2012

Summary

Labour law — Workmen’s compensation — Computation of compensation — Whether compensation properly assessed — Role of District Labour Officer — Failure to call material witness — Evidence — Burden of proof — Civil cases — Plaintiff’s duty to establish claim — Shifting burden — Failure to adduce material evidence — Practice and procedure — Fraud — Requirement that fraud be specifically pleaded and particularised — Whether delay in payment amounts to fraud — Interest — Claim for interest on delayed compensation — Whether payable in absence of proof of cause of delay — Jurisdiction — High Court — Whether jurisdiction ousted under Workmen’s Compensation Act, 1987 (PNDCL 187) Headnote The plaintiff, widow of a deceased employee of the defendant company, sued for recovery of an alleged shortfall in compensation payable under the Workmen’s Compensation Act, 1987 (PNDCL 187) following her husband’s death in a work-related accident. The defendant had paid compensation in two instalments based on assessments by the District Labour Officer. The plaintiff contended that the compensation was underpaid, that the defendant acted fraudulently in withholding part of it, and that she was entitled to interest due to delay in payment. The defendant argued that it paid all sums as directed by the District Labour Officer and denied any fraud. It also challenged the competence of the action and the jurisdiction of the High Court. Held Dismissing the claim: 1. On burden of proof The burden of proof in civil cases lies on the party asserting a claim. The plaintiff failed to adduce sufficient evidence to establish that there was any outstanding balance due her. 2. On failure to call a material witness The District Labour Officer, who computed the compensation and directed payments, was a material witness. The plaintiff’s failure to call him to testify was fatal to her claim of underpayment. 3. On fraud Fraud must be specifically pleaded with particulars and proved by evidence of dishonest misrepresentation. Mere delay in payment or reliance on official computation does not amount to fraud. The plaintiff failed to establish fraud. 4. On jurisdiction The Workmen’s Compensation Act did not expressly oust the jurisdiction of the High Court; therefore, by virtue of Article 140(1) of the 1992 Constitution, the High Court had jurisdiction to entertain the action. 5. On claim for interest Interest is not awardable where there is no clear evidence establishing when the money became due or who caused the delay in payment.

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