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Uganda Judgment

HC: Land Division (Uganda)

Alli Maishalla and 5 Others v Basheza (Land Civil Suit 5 of 2022) [2023] UGHCLD 320 (17 July 2023)

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01

Holding and result

The court upheld the preliminary objection that the respondent's affidavit in reply was filed out of time without leave of court, rendering it incompetent and struck out. Consequently, the application was heard as unopposed. The court found that the Chief Magistrate failed to consider documentary evidence of the applicants' possession of the suit land and that the respondent did not address the substantive issues. The court concluded that the applicants had proved their case for revision, and the land should be released from attachment. Costs were awarded to the applicants.

Court disposition

application allowed

Orders

  • The respondent's affidavit in reply is struck out for being filed out of time without leave.
  • The application is allowed in its entirety.
  • The applicants' land is released from attachment.
  • Costs are granted to the applicants.

02

Material facts

Parties

Alli Maishalla & 5 Others

Applicant

Basheza Ramathan

Respondent

03

Procedural history

  1. Posture

    Miscellaneous Application / Ruling

04

Questions and positions

Legal issues

Party arguments

Applicant
The applicants argued that the respondent's affidavit in reply was filed out of time without leave of court, contrary to the Civil Procedure Rules, and should be struck out. They further contended that the Chief Magistrate failed to consider documentary evidence showing the applicants' possession of the suit land, resulting in a decision attended by material irregularity and injustice.
Respondent
The respondent filed a reply affidavit but did not seek leave for late filing and did not address the substantive issues raised by the applicants regarding possession and the alleged irregularities in the Chief Magistrate's decision.

05

Court’s reasoning

  1. 01

    Order 52 Rule 3 of the Civil Procedure Rules; Stop and See (U) Ltd v Tropical Africa Bank Ltd MA No. 33 of 2012

    A reply or defence to an application must be filed within fifteen days as per the Civil Procedure Rules; failure to do so without leave renders the reply incompetent.

  2. 02

    Section 83 of the Civil Procedure Act

    The High Court has power to revise decisions of lower courts where there is material irregularity or injustice.

06

Ratio, limits and disposition

Ratio decidendi

The court upheld the preliminary objection that the respondent's affidavit in reply was filed out of time without leave of court, rendering it incompetent and struck out. Consequently, the application was heard as unopposed. The court found that the Chief Magistrate failed to consider documentary evidence of the applicants' possession of the suit land and that the respondent did not address the substantive issues. The court concluded that the applicants had proved their case for revision, and the land should be released from attachment. Costs were awarded to the applicants.

Obiter and limits

  • Strict compliance with procedural timelines for filing affidavits is mandatory and failure to seek leave for late filing is fatal to the pleadings.
  • Where a party fails to rebut the applicant's evidence, the court may proceed to grant the orders sought if satisfied on the merits.

Court disposition

application allowed

  • The respondent's affidavit in reply is struck out for being filed out of time without leave.
  • The application is allowed in its entirety.
  • The applicants' land is released from attachment.
  • Costs are granted to the applicants.

Source and reliance status

HC: Land Division (Uganda)

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Judgment text

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Source document

HC: Land Division (Uganda)

Judgment

[2023] UGHCLD 320

REPUBLIC OF UGANDA IN THE HIGH COURT OF UGANDA AT TORORO HCT-19-LD-CR-0005 OF 2022

ALLI MAISHALLA 5 ORS ::::::::::::::::::::::::::::::::::::::::APPLICANT VERSUS

BASHEZA RAMATHAN::::::::::::::::::::::::::::::::::::::::RESPONDENT

RULING

BEFORE: HON. DR. JUSTICE HENRY I KAWESA

This matter was filed before me by Notice of Motion.

The matter (application) seeks orders *inter alia* revising a decision by the Chief Magistrate Busia under Miscellaneous Application No. 43/2017 (*referred to as Miscellaneous Application No 43/2017*) for;

- i) Objector proceedings for a warrant to give vacant possession of the suit property and; - ii) That costs of the application be provided for.

The Miscellaneous Application is supported by an affidavit filed by the Applicants. The complaint is that while dismissing the application, the Magistrate acted with material irregularity or injustice, and that the application is brought without delay.

The Respondent filed a reply which Counsel for the Applicant by a Preliminary Objection wants Court to struck out. I resolve the matters as here below:

1. Preliminary Objection on affidavit in Reply.

The Rules that govern pleadings are set out in the Civil Procedure Rules. Once the Defendant is served service must follow the strict position postulated in the Rules.

For emphasis the application before Court was generated by Notice of Motion. This is governed by Section 83(c), and Order 52 Rule 3 of the Civil Procedure Rules. The time required for a reply to pleadings generated as above is fixed to 15 days. This Court has held so many times in different cases guided by the principle in *Stop and See (U) Ltd versus Tropical Africa Bank Ltd; MA NO. 33 of 2012* and the case of *Spring Wood Capital Patroness Ltd versus Twed Consulting Co. Ltd (as quoted) refers;*

*"that a reply or defence to an application has to be filed within fifteen days, failure to do so puts any defence so is sought"*.

No leave was sought herein.

I do uphold the preliminary Objection.

- 2. The matter therefore is heard as if no reply was filed. The effect is that the Notice of Motion and affidavit in support are not rebutted. Given that position and following Section 83 of the Civil Procedure Act, I find that: - (i) the Learned Trial Magistrate failed to take note of the fact that there was documentary evidence before Court that Applicants were in possession of the land subject of objection.

(ii) I have noted the fact that Civil Suit No. 25/2016, 26/2016, and 6/2020 were dismissed by the Chief Magistrate on 23th November 2022.

I also take note of the fact that the Respondent has not addressed the issues raised constituting the failure by the Learned Trial Magistrate to address the matters before him.

In the result, I do find that this application is proved.

The grounds raised by the Applicant are noted and allowed in their entirety. The Applicant's land should be accordingly released from attachment.

Costs granted to the Applicants.

I so order.

…………………………….. Hon. Dr. Henry I Kawesa JUDGE 17/07/2023

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Authorities

Authorities used by the court

Cases, legislation, regulations, and constitutional provisions identified in the available record.

Stop and See (U) Ltd v Tropical Africa Bank Ltd MA No. 33 of 2012

Case cited

Spring Wood Capital Patroness Ltd v Twed Consulting Co. Ltd

Case cited

Section 83 of the Civil Procedure Act

Legislation

Legislation referenced in the available case record.

Order 52 Rule 3 of the Civil Procedure Rules

Legislation

Legislation referenced in the available case record.

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