It is the requirement of law and practice of law in Tanzania that whoever applies for an extension of time to file any matter in court of law has to count for each day of delay. Also, the court of law developed a number of decisions requiring the applicants to count for each day of delay. Also, it's well recognized that the transfer of a prisoner from one prison to another is good ground for extension of time.

but the court in case of Michael Maisha @ Wakasongoro vs Director of The Public Prosecutions (Criminal Application No. 28358311 of 2025) [2026] TZCA 874 (6 August 2026) add a new requirement to wit, such delay has to to be caused by negligent/ lacked diligence.

Prison transfer alone did not justify an extension; the applicant failed to account for the delay and lacked diligence. These can hinder an applicant from getting extantion of time.