MULUNGUSHI UNIVERSITY

SCHOOL OF BUSINESS STUDIES

DEPARTMENT OF LAW, LABOUR AND HRM

AN ANALYSIS OF THE POWERS OF THE DPP VIS-A-VIS NOLLE PROSEQUI

NAME : MALAMA FRANCIS

STUDENT NUMBER : 201701328

COURSE CODE : BLL 401

COURSE NAME : Law Research

LECTURER : Ms Josephine

EMAIL : [email protected]
Contents
CHAPTER 1: BACKGROUND TO THE STUDY.........................................................1
1.1 Introduction....................................................................................................1
1.2 Background of the Study....................................................................................2
1.3 Statement of the Problem....................................................................................2
1.4 Purpose of the Study.........................................................................................3
1.5 Research Objectives..........................................................................................3
1.6 Research Questions...........................................................................................3
1.7 Significance of the Study....................................................................................4
1.8 Scope of the Study............................................................................................4
1.9 Limitations of the Study.....................................................................................4
CHAPTER 2: LITERATURE REVIEW..................................................................5
2.1 Introduction...................................................................................................5
2.2 The Concept of Nolle Prosequi............................................................................5
2.3 Theoretical Framework....................................................................................6
2.4 Legal Framework for Nolle Prosequi in Zambia.......................................................7
2.5 Empirical Studies on the Application of Nolle Prosequi..............................................7
2.6 Issues Surrounding Nolle Prosequi in Zambia..........................................................8
2.7 Gaps in Existing Literature.................................................................................9
2.8 Conceptual Framework......................................................................................9
CHAPTER 3: METHODOLOGY............................................................................10
3.1 Introduction..................................................................................................10
3.2 Research Approach.........................................................................................10
3.3 Study Area...................................................................................................11
3.4 Study Population and Sample Selection................................................................11
3.5 Data Collection Tools......................................................................................12
3.6 Methods of Data Analysis.................................................................................13
3.7 Ethical Considerations.....................................................................................13
3.8 Limitations...................................................................................................13
References........................................................................................................15
CHAPTER 1: BACKGROUND TO THE STUDY

1.1 Introduction

The administration of justice plays a critical role in ensuring the rule of law and upholding public
trust in any legal system. Prosecutorial discretion, as exercised by the Director of Public
Prosecutions (DPP), is a cornerstone of this process, allowing the DPP to make crucial decisions
regarding the initiation, continuation, and discontinuation of criminal proceedings (Lusaka
Times, 2017). Among the powers vested in the DPP in Zambia is the authority to enter a nolle
prosequi, a declaration that effectively discontinues criminal proceedings. This power is not only
significant but also subject to intense scrutiny due to its impact on the administration of justice
and the perception of prosecutorial independence (Kabisa, 2021).

The exercise of nolle prosequi is intended to prevent unwarranted or unjust prosecutions,

ensuring that prosecutions align with public interest and evidentiary sufficiency (Phiri, 2015).
However, its application, particularly in high-profile and politically sensitive cases, has raised
questions about the transparency, accountability, and impartiality of prosecutorial decisions
(Mensah, 2006). Instances where this power has been invoked have led to public debates about
its potential misuse and the balance between prosecutorial independence and public
accountability (Mutonyi, 2007). These concerns are critical to understanding the broader
implications of nolle prosequi on Zambia’s criminal justice system.

This study focuses on the legal and practical implications of the DPP's power to enter a nolle
prosequi, examining its historical context, legal framework, and application in practice. It aims
to evaluate how this discretionary power has been utilized, its impact on justice delivery, and the
public perception of prosecutorial independence (Lusaka Times, 2017). Understanding how this
discretion is applied is essential for informing legal reforms aimed at enhancing accountability,
fairness, and public confidence in Zambia's justice system.
1.2 Background of the Study

The power to enter a nolle prosequi is a critical tool for prosecutors in common law jurisdictions,
including Zambia. Historically, this power was established to protect individuals from
unwarranted or malicious prosecutions while preserving the independence of the prosecutorial
process (Mensah, 2006). In Zambia, the authority to invoke a nolle prosequi is explicitly
provided for under Article 180 of the Constitution and further elaborated in the Criminal
Procedure Code (Zambia Constitution, 2016). It empowers the DPP to discontinue prosecutions
at any stage before judgment is rendered, emphasizing prosecutorial discretion as a means to
uphold justice and fairness (Kabisa, 2021).

Despite its intended purpose, the application of nolle prosequi has sparked concerns about its
potential misuse, particularly in cases involving political figures or high-profile individuals
(Phiri, 2015). Historically, the exercise of this power in such contexts has led to public outcry,
with accusations of bias, favoritism, or political interference (Lusaka Times, 2017). The lack of
transparency and accountability in prosecutorial decisions has further fueled debates about the
appropriateness of this power in its current form (Mutonyi, 2007). This study seeks to address
these concerns by analyzing the legal and practical dimensions of nolle prosequi in Zambia and
its implications for governance and public trust.

1.3 Statement of the Problem

The discretionary power of the DPP to enter a nolle prosequi is intended to uphold justice by
discontinuing prosecutions that are not in the public interest or that lack sufficient evidence
(Zambia Constitution, 2016). However, the exercise of this power has been criticized for its
potential to undermine public trust in the criminal justice system (Phiri, 2015). In Zambia, high-
profile cases where nolle prosequi has been invoked have intensified concerns about its potential
misuse, particularly in politically sensitive contexts (Mensah, 2006). Questions have arisen
regarding the impartiality of the DPP, the transparency of prosecutorial decisions, and the
accountability mechanisms in place to prevent abuse (Kabisa, 2021).

There is a significant knowledge gap in understanding how the DPP exercises this power, the
rationale behind discontinuing certain prosecutions, and the broader implications for justice
delivery (Mutonyi, 2007). This gap underscores the need for a comprehensive analysis of the
legal framework governing nolle prosequi, its application in practice, and its impact on public
confidence in the justice system (Phiri, 2015). Addressing these issues is essential for
strengthening prosecutorial accountability, safeguarding the rule of law, and ensuring equitable
justice in Zambia.

1.4 Purpose of the Study

The purpose of this study is to critically examine the legal framework that governs the DPP's
authority to enter a nolle prosequi in Zambia (Zambia Constitution, 2016). It seeks to evaluate
how this power has been applied in practice, particularly in high-profile cases, and to assess its
implications for justice delivery, prosecutorial independence, and public trust (Phiri, 2015). By
addressing these aspects, the study aims to identify areas for potential reform to enhance
transparency, accountability, and the overall effectiveness of Zambia’s criminal justice system
(Kabisa, 2021).

1.5 Research Objectives

2. To analyze the constitutional and statutory provisions that define the DPP's authority to
enter a nolle prosequi
3. To evaluate how the DPP has exercised the nolle prosequi power in practice, focusing on
notable case studies
4. To assess the impact of the DPP’s use of nolle prosequi on justice delivery and public
perception of prosecutorial independence

1.6 Research Questions

1. What are the constitutional and legal provisions that govern the DPP’s power to enter a
nolle prosequi in Zambia?
2. How has the DPP applied the nolle prosequi power in practice, particularly in high-
profile cases?
3. What are the implications of the DPP’s exercise of nolle prosequi on justice delivery and
public trust in the legal system?
1.7 Significance of the Study

This study is significant as it addresses a critical aspect of Zambia’s criminal justice system.
First, it contributes to the discourse on prosecutorial discretion and accountability, which are
essential for upholding the rule of law and maintaining public trust. Second, the findings provide
valuable insights into the transparency and fairness of prosecutorial decisions, highlighting areas
where reforms may be necessary. Third, the study offers a comparative perspective by examining
the application of nolle prosequi in other African jurisdictions, which can inform best practices
for Zambia. Ultimately, the study supports efforts to strengthen governance, improve the
administration of justice, and promote public confidence in Zambia’s legal system.

1.8 Scope of the Study

The study focuses on the legal framework governing nolle prosequi in Zambia, as articulated in
the Constitution and the Criminal Procedure Code. It examines selected high-profile cases where
this power has been invoked, analyzing the rationale behind these decisions and their
implications for justice and governance. Additionally, the study includes comparative
perspectives from African jurisdictions such as Ghana, Nigeria, Kenya, South Africa, and
Uganda to provide broader insights into prosecutorial discretion. The research is limited to
qualitative analysis of legal documents, case studies, and stakeholder perspectives, excluding
quantitative data collection.

1.9 Limitations of the Study

The study may encounter certain limitations. Restricted access to court judgments and official
records could constrain the depth of the analysis. Furthermore, qualitative data interpretation,
such as stakeholder interviews, may introduce subjective biases. Efforts to address these
challenges include triangulating data from multiple sources and maintaining transparency in data
analysis. Differences in legal and political contexts across jurisdictions may also limit the direct
applicability of comparative findings to Zambia’s legal system.
CHAPTER 2: LITERATURE REVIEW

2.1 Introduction

This chapter explores the theoretical and empirical literature surrounding the concept,
application, and implications of nolle prosequi. The review begins with an overview of nolle
prosequi as a legal concept, followed by an examination of the theoretical frameworks relevant
to its exercise. It also reviews legal and empirical studies on the application of nolle prosequi in
Zambia and other jurisdictions, highlighting issues of transparency, accountability, and public
trust. The chapter concludes with an analysis of the gaps in existing literature and a conceptual
framework linking the theoretical and empirical insights to the study's objectives and research
questions.

2.2 The Concept of Nolle Prosequi

The term nolle prosequi, derived from Latin meaning "to be unwilling to prosecute," refers to a
formal declaration by which a prosecutor discontinues criminal proceedings against an accused
individual. This legal mechanism permits the prosecution to withdraw charges at any stage
before judgment, effectively terminating the case. Its primary purpose is to prevent the
continuation of prosecutions that lack sufficient evidence, are not in the public interest, or where
further proceedings would be unjust (Mensah, 2006). This concept has been integral to common
law jurisdictions, including Zambia, where the Director of Public Prosecutions (DPP) exercises
this discretionary power under Article 180 of the Constitution and the Criminal Procedure Code
(Zambia Constitution, 2016).

The use of nolle prosequi is intended to balance prosecutorial independence with the principles
of justice and fairness. However, the discretionary nature of this power has sparked considerable
debate, particularly in politically sensitive cases where its application has been perceived as
arbitrary or biased (Phiri, 2015). The need for transparency and accountability in the exercise of
nolle prosequi underscores its importance within Zambia's justice system.
2.3 Theoretical Framework

The exercise of nolle prosequi can be analyzed through several theoretical lenses that help
explain its purpose, application, and potential challenges. Legal positivism, the rule of law, and
public interest theory are the three primary frameworks relevant to this study.

Legal positivism emphasizes the legitimacy of the DPP’s authority to invoke nolle prosequi as a
power explicitly granted by statutory and constitutional provisions. According to Hart (1961),
law derives its validity from established legal rules, irrespective of moral considerations. Under
this framework, the DPP’s discretion to discontinue prosecutions is seen as a lawful exercise of
authority, provided it aligns with procedural requirements outlined in the Constitution and
Criminal Procedure Code.

The rule of law underscores the importance of accountability and equality before the law in
prosecutorial decisions. Dicey (1959) argues that the rule of law requires transparency and
consistency in the application of legal powers. This theory highlights the potential risks of abuse
or misuse of nolle prosequi if the DPP’s decisions lack oversight or are influenced by external
factors. Ensuring that decisions are impartial and adhere to established legal principles is critical
for maintaining public trust in the justice system.

Public interest theory focuses on the broader societal implications of prosecutorial discretion.
Mutonyi (2007) argues that the DPP’s decisions should prioritize societal welfare and public
trust. From this perspective, the exercise of nolle prosequi must balance legal considerations
with the need to uphold public confidence in the justice system. This framework provides a lens
for evaluating whether prosecutorial actions genuinely serve the public interest or undermine it.

These theoretical frameworks collectively provide a foundation for understanding the principles
that should guide the DPP’s use of nolle prosequi in Zambia. They also highlight the challenges
of ensuring that this discretionary power is exercised transparently and equitably.
2.4 Legal Framework for Nolle Prosequi in Zambia

In Zambia, the DPP’s authority to enter a nolle prosequi is enshrined in Article 180 of the
Constitution, which grants the DPP discretion to discontinue criminal proceedings before
judgment. This constitutional provision is supported by the Criminal Procedure Code, which
outlines the procedural aspects of exercising this power (Zambia Constitution, 2016). The legal
framework reflects the principles of prosecutorial independence, allowing the DPP to halt
proceedings when further prosecution is deemed unnecessary or unjust.

Despite the clarity of these provisions, the legal framework has been criticized for lacking
adequate checks and balances to ensure accountability. Kabisa (2021) argues that the absence of
explicit oversight mechanisms increases the risk of misuse, particularly in cases involving
political figures or high-profile individuals. Critics contend that prosecutorial independence must
be balanced with accountability to prevent decisions that may appear arbitrary or influenced by
external pressures. These concerns underscore the need for reforms that strengthen the
transparency and oversight of prosecutorial decisions.

2.5 Empirical Studies on the Application of Nolle Prosequi

Empirical studies provide valuable insights into the application of nolle prosequi in Zambia and
other jurisdictions. In Zambia, Phiri (2015) examined cases where nolle prosequi was invoked,
such as The People v. Fredrick Chiluba. The study found that the DPP’s decision to discontinue
proceedings often attracted public criticism, particularly in politically sensitive cases. The lack of
transparency in these decisions raised questions about the impartiality and integrity of
prosecutorial discretion.

In Ghana, Mensah (2006) studied the application of nolle prosequi in the Woyome Judgment
Debt Case, where charges of corruption were dropped. The study highlighted the need for
reforms to ensure greater accountability in prosecutorial decisions. Similarly, in Nigeria,
Ejimofor (2015) analyzed the Supreme Court’s ruling in State v. Ilori (1983), which affirmed the
Attorney-General’s discretion to enter a nolle prosequi. The study emphasized the potential for
misuse in politically charged cases and the importance of judicial oversight.

In Kenya, Oloo (2011) explored the Thomas Cholmondeley Case, where nolle prosequi was
invoked in a manslaughter case involving a politically influential figure. The study highlighted
public perceptions of privilege influencing prosecutorial decisions and its impact on public trust.
In Uganda, Mutonyi (2007) analyzed the Dr. Kizza Besigye Treason Case, noting that the
decision to discontinue charges against a prominent opposition leader raised concerns about the
politicization of prosecutorial discretion.

In South Africa, the Jacob Zuma Corruption Charges Case provides a comparative
perspective. The National Prosecuting Authority’s decision to drop corruption charges against
Zuma, later overturned by the courts, highlighted the need for judicial oversight to ensure
fairness and accountability in prosecutorial decisions (South African Constitutional Court, 2016).
These studies underscore the complexities of exercising nolle prosequi and the challenges of
balancing independence with public accountability.

2.6 Issues Surrounding Nolle Prosequi in Zambia

The exercise of nolle prosequi in Zambia raises critical issues related to transparency, political
influence, and public trust. One major concern is the perceived lack of transparency in
prosecutorial decisions. Many cases are discontinued without detailed public explanations,
leading to accusations of arbitrariness (Phiri, 2015). This lack of transparency undermines public
confidence in the justice system and fuels suspicions of bias or favoritism.

Political influence is another significant issue. High-profile cases, such as The People v.
Fredrick Chiluba, have raised concerns about the potential for political considerations to affect
prosecutorial decisions. Critics argue that such decisions erode trust in the impartiality and
independence of the DPP’s office (Kabisa, 2021). Addressing these issues requires reforms that
enhance oversight and ensure that decisions to invoke nolle prosequi are made transparently and
in the public interest.
Public trust is also a critical factor. Frequent or controversial use of nolle prosequi can diminish
confidence in the legal system, as citizens may perceive that justice is not being served equitably.
Strengthening the mechanisms for accountability and transparency is essential for restoring
public faith in the justice system and ensuring that prosecutorial decisions align with societal
expectations.

2.7 Gaps in Existing Literature

Despite extensive legal and theoretical discourse on nolle prosequi, several gaps remain.
Empirical research on the practical application of nolle prosequi in Zambia is limited,
particularly in terms of analyzing case outcomes and public perceptions (Phiri, 2015).
Additionally, studies on the effectiveness of oversight mechanisms in ensuring accountability
and preventing misuse are insufficient (Kabisa, 2021). Comparative studies on the application of
nolle prosequi across different jurisdictions, especially in politically sensitive cases, are also
lacking (Mensah, 2006). Addressing these gaps is crucial for informing reforms aimed at
enhancing prosecutorial accountability and transparency.

2.8 Conceptual Framework

This study adopts a conceptual framework that integrates theoretical and empirical insights to
examine the relationship between the DPP’s discretionary power to invoke nolle prosequi and its
impact on justice delivery, accountability, and public trust. The framework highlights the need to
analyze the legal framework governing nolle prosequi, evaluate its practical application in high-
profile cases, and assess its implications for public confidence in the justice system. By linking
theoretical and empirical literature to the study’s objectives, the framework provides a structured
approach to addressing the challenges and opportunities associated with nolle prosequi in
Zambia.
CHAPTER 3: METHODOLOGY

3.1 Introduction

This chapter outlines the methodological framework employed to examine the legal framework,
practical application, and implications of nolle prosequi in Zambia. The chapter begins with a
description of the research approach, followed by an explanation of the study area, population,
and sample selection. The tools and techniques used for data collection are then detailed, along
with the methods of data analysis. Ethical considerations and limitations of the study are also
addressed. By adopting a qualitative approach and incorporating case study analysis, the
methodology ensures a comprehensive examination of the research objectives.

3.2 Research Approach

The study adopts a qualitative research approach, which is suitable for exploring the
complexities of legal frameworks, interpreting case law, and understanding stakeholder
perspectives. Qualitative research facilitates in-depth analysis of textual and interview data,
which is essential for examining nolle prosequi in Zambia. This approach allows for the
identification of patterns, themes, and broader implications, making it particularly useful for
analyzing the discretionary powers of the DPP in both legal and societal contexts (Creswell,
2014).

To enhance the depth of the qualitative analysis, the study incorporates a case study strategy.
This approach provides a detailed examination of specific instances where nolle prosequi has
been invoked, offering contextualized insights into the rationale behind prosecutorial decisions
and their societal impact. For example, the case of The People v. Fredrick Chiluba is analyzed to
explore the implications of discontinuing criminal proceedings in high-profile cases. By using
case studies, the research connects theoretical concepts with practical applications, ensuring a
thorough understanding of the topic (Phiri, 2015).

3.3 Study Area

The research focuses on Zambia, which serves as the primary case for analyzing the legal and
practical dimensions of nolle prosequi. Zambia’s legal system, rooted in common law traditions,
provides a framework for the discretionary powers of the DPP. This makes Zambia an ideal
context for studying the balance between prosecutorial independence and accountability.

The study also incorporates comparative perspectives from other African jurisdictions, including
Ghana, Nigeria, Kenya, South Africa, and Uganda. These countries share a common law
heritage, offering valuable points of comparison in terms of their prosecutorial systems and the
use of nolle prosequi. For instance, Ghana’s Section 54 of the Criminal Procedure Code and
Nigeria’s Section 174 of the Constitution provide legal provisions similar to those in Zambia,
making these jurisdictions particularly relevant for comparison (Mensah, 2006; Ejimofor, 2015).
By situating Zambia within this broader African context, the study identifies best practices and
lessons that could inform reforms in the Zambian legal framework.

3.4 Study Population and Sample Selection

The study targets three main groups: legal documents, court cases, and stakeholders.

The first group includes primary and secondary legal texts such as the Constitution of Zambia,
the Criminal Procedure Code, and judgments from relevant cases. These documents provide the
foundation for analyzing the legal framework governing nolle prosequi and understanding its
procedural application. The second group consists of high-profile court cases, including The
People v. Fredrick Chiluba in Zambia and State v. Ilori in Nigeria. These cases illustrate the
practical application of nolle prosequi and its implications in politically sensitive contexts. The
third group includes stakeholders, such as legal practitioners, judicial officers, and academics,
whose insights offer a nuanced understanding of prosecutorial discretion.

The study employs purposive sampling to select cases and participants. High-profile cases are
chosen for their significance in shaping public discourse on the use of nolle prosequi.
Participants are selected based on their expertise in constitutional law and criminal justice,
ensuring that the study captures diverse perspectives and critical insights. This sampling method
is appropriate for addressing the research objectives and ensuring the relevance of the data
collected (Creswell, 2014).

3.5 Data Collection Tools

The study utilizes a combination of document analysis, semi-structured interviews, and case
study protocols to gather data.

Document analysis involves a systematic review of primary legal texts, including the
Constitution of Zambia and the Criminal Procedure Code, as well as secondary sources such as
academic articles and reports. These documents are analyzed to identify the legal provisions
governing nolle prosequi and to understand its application in practice. For instance, Phiri’s
(2015) analysis of prosecutorial decisions in Zambia provides valuable context for understanding
the political and legal dimensions of nolle prosequi.

Semi-structured interviews are conducted with legal practitioners, judicial officers, and
academics. These interviews explore participants’ experiences and opinions regarding the use of
nolle prosequi, focusing on its transparency, accountability, and societal impact. An interview
guide is developed to ensure consistency across interviews while allowing flexibility to delve
into specific topics. Questions address key issues such as the perceived independence of the DPP
and the implications of discontinuing high-profile cases (Kabisa, 2021).

A structured case study protocol is used to systematically analyze selected cases. This approach
ensures consistency in examining the rationale behind prosecutorial decisions, the outcomes of
discontinued cases, and their broader implications. Comparative cases, such as the Woyome
Judgment Debt Case in Ghana and the Jacob Zuma Corruption Charges Case in South
Africa, are also analyzed to provide additional insights (Mensah, 2006; South African
Constitutional Court, 2016).

3.6 Methods of Data Analysis

The study employs thematic analysis to identify recurring themes in the data, such as legal
provisions, practical applications, and the implications of nolle prosequi. Thematic analysis is
particularly effective for analyzing qualitative data, enabling the identification of patterns and
insights that inform the research objectives (Braun & Clarke, 2006).

Comparative analysis is used to evaluate the similarities and differences in the application of
nolle prosequi across Zambia and other African jurisdictions. This method provides a framework
for identifying best practices and lessons that could inform reforms in Zambia. For instance, the
transparency mechanisms in South Africa’s prosecutorial system serve as a potential model for
Zambia (South African Constitutional Court, 2016).

To ensure the validity and reliability of findings, the study employs triangulation, cross-verifying
data from legal documents, interviews, and case studies. This approach reduces bias and
enhances the robustness of the analysis, ensuring that the findings are well-grounded and
credible (Creswell, 2014).

3.7 Ethical Considerations

The study adheres to ethical research principles to ensure the integrity of the process. Informed
consent is obtained from all participants, who are fully informed about the study’s purpose and
their right to withdraw at any time. Confidentiality is maintained by anonymizing interview data
to protect participants’ identities. Objectivity is prioritized in data analysis, with the researcher
ensuring impartiality in interpreting findings. Additionally, proper citation of sources, including
legal documents and academic works, ensures academic integrity (Yin, 2018).

3.8 Limitations

The study acknowledges potential limitations. Access to certain legal documents and court
judgments may be restricted, limiting the comprehensiveness of the analysis. Additionally, the
subjective nature of qualitative data, particularly in stakeholder interviews, could introduce bias.
However, triangulation is employed to mitigate this risk and ensure the validity of the findings.
Differences in legal and political contexts across jurisdictions may also limit the applicability of
comparative findings to Zambia.
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