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Uganda Judgment

East African Court of Appeal

Crown v Gatune wa Kamau (Revision Case No. 138 of 1927) [1927] EACA 30 (1 January 1927)

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Source document

01

Holding and result

The court held that maintaining cattle on a farm in excess of the number allowed by contract does not constitute a criminal offence under the Resident Native Labourers' Ordinance. The existence of excess cattle may provide grounds for rescission of the contract between the occupier and the squatter, but it does not render the squatter criminally liable. Accordingly, the conviction was quashed and the fine ordered to be refunded.

Court disposition

conviction quashed

Orders

  • The conviction is quashed.
  • The fine is to be refunded.

02

Material facts

Parties

Crown

Appellant

Gatune wa Kamaij

Respondent

03

Procedural history

  1. Posture

    Criminal Appeal / Judgment

04

Questions and positions

Legal issues

Whether maintaining cattle on a farm in excess of the number allowed by contract constitutes a criminal offence under the Resident Native Labourers' Ordinance.

Party arguments

Applicant
The Crown argued that the respondent maintained more cattle on the farm than permitted by the contract, which should constitute an offence under the Resident Native Labourers' Ordinance.
Respondent
The respondent contended that exceeding the contractual number of cattle is not a criminal offence and, at most, may be a civil matter between the occupier and the squatter.

05

Court’s reasoning

  1. 01

    Resident Native Labourers' Ordinance, section 10

    There is no criminal offence for maintaining cattle on a farm in excess of the number allowed by contract under the Resident Native Labourers' Ordinance.

06

Ratio, limits and disposition

Ratio decidendi

The court held that maintaining cattle on a farm in excess of the number allowed by contract does not constitute a criminal offence under the Resident Native Labourers' Ordinance. The existence of excess cattle may provide grounds for rescission of the contract between the occupier and the squatter, but it does not render the squatter criminally liable. Accordingly, the conviction was quashed and the fine ordered to be refunded.

Obiter and limits

  • The fact of having excess cattle may be a ground for rescission of the contract but does not amount to a criminal offence.

Court disposition

conviction quashed

  • The conviction is quashed.
  • The fine is to be refunded.

Source and reliance status

East African Court of Appeal

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Source document

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Judgment text

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Source document

East African Court of Appeal

Judgment

[1927] EACA 30

Before SHERIDAN, ;f •.

CROWN

GATUNE wa KAMAIJ .

.1:tflvision C11se 138 / 1 O'..:l7.

The Resident ¥afr•e Labourers' Ordinam,e, section !();-movement and branding of resident natives' cattle.

*Held* : -That there is no such offence as maintaining · cattle on· a farin in excess of the number allowed by contract.

In the original case (Criminal Case. 87/1927 in. the Third. Class Court at· \_Fort Hall) the accused was ccnvilted .)f having maintained on a farm cattle 'in excess of the number .allowed. on his contract.

0RDER.-There is no such offence as mainfaining cattle on a. farm in excess of the number allowed by contract. The. fact of having an excess may be a ground for rescission of the contract between· the occupier. and the squatter but it does not , render the latter liable to conviction ..

The conviction is quashed and the fine directed to be refunded.

*v.*

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Authorities

Authorities used by the court

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

Resident Native Labourers' Ordinance, section 10

Legislation

Legislation referenced in the available case record.

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