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Uganda Judgment

Court of Appeal of Uganda

Sarah Anena v Institute of Certified Public Accountants of Uganda and Others (Constitutional Petition No. 0033 of 2021) [2025] UGCA 163 (15 May 2025)

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Professional case brief

Research organized from the available case record

Source document

01

Holding and result

The petition was dismissed for want of prosecution because the petitioner failed to comply with the court's directions regarding amendment, service, and filing of responses. The court found that the directions given to the parties had not been adhered to, which constituted a failure to prosecute the petition. As a result, the petition could not proceed and was dismissed, with no orders as to costs.

Court disposition

petition dismissed for want of prosecution

Orders

  • The petition is dismissed for want of prosecution.
  • No orders as to costs.

02

Material facts

Parties

Sarah Anena

Applicant Counsel: Elizabeth Yaledi

Institute of Certified Public Accountants of Uganda

Respondent Counsel: Martin Kakuru

Minister of Finance; Hon. Kasaijja Matia

Respondent Counsel: Bichachi Ojambo

Registrar of Accountants; Derrick Nkajja

Respondent Counsel: Martin Kakuru

Amounts and remedies

  • Amount in Controversy (ugx): UGX 18,078

03

Procedural history

  1. Posture

    Constitutional Petition / Ruling on Dismissal for Want of Prosecution

04

Questions and positions

Legal issues

Party arguments

Applicant
The petitioner alleged that the 1st respondent acted ultra vires by restricting direct membership of the Institute of Certified Public Accountants of Uganda to only members of accounting societies from within the East Africa Region, which she contended was unconstitutional. She sought constitutional interpretation under Article 137.
Respondent
The 1st and 3rd respondents argued that the petition did not disclose a cause of action. The 2nd respondent contended that the petition did not raise any matters for constitutional interpretation under Article 137 and was wrongly joined as a party.

05

Court’s reasoning

  1. 01

    Constitutional Court (Petitions and References) Rules, 2005

    A petition must be prosecuted in accordance with the directions of the court; failure to do so amounts to want of prosecution.

  2. 02

    Article 137 of the Constitution of Uganda

    Only matters that raise constitutional interpretation under Article 137 are properly before the Constitutional Court.

06

Ratio, limits and disposition

Ratio decidendi

The petition was dismissed for want of prosecution because the petitioner failed to comply with the court's directions regarding amendment, service, and filing of responses. The court found that the directions given to the parties had not been adhered to, which constituted a failure to prosecute the petition. As a result, the petition could not proceed and was dismissed, with no orders as to costs.

Obiter and limits

  • The court noted that the 2nd respondent was wrongly added as a party and that the Attorney General should have been joined instead.
  • Directions for amendment and scheduling were given but not followed, demonstrating procedural non-compliance.

Court disposition

petition dismissed for want of prosecution

  • The petition is dismissed for want of prosecution.
  • No orders as to costs.

Source and reliance status

Court of Appeal of Uganda

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Source document

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Judgment text

The complete available source text.

Source document

Court of Appeal of Uganda

Judgment

[2025] UGCA 163

THE REPUBLIC OF UGANDA

IN THE CONSTITUTIONAL COURT OF UGANDA AT KAMPALA

Coram: Kiryabwire; Kibeedi; Gashirabake; Kihika & Tibulya, JJ. CC

Constitutional Petition No. 0033 of 2021

PETITIONER Sarah Anena ...................................

Versus

- 1. Institute of Certified Public Accountants of Uganda - 2. Minister of Finance; Hon. Kasaijja Matia - 3. Registrar of Accountants; Derrick Nkajja ..................................

RULING OF COURT

- 1. The petitioner, Sarah Anena brought this petition under Article 137 (1), (3) (a) (b) and (4) of the Constitution and the Constitutional Court (Petitions and References) Rules, 2005. It was alleged that the 1<sup>st</sup> respondent acted ultra vires in restricting direct membership of the institute to only members of accounting societies from within the East Africa Region. - 2. The petition is supported by the affidavit of the petitioner. - 3. The $1^{st}$ and $3^{rd}$ respondents, contending that the petition does not disclose a cause of action opposed it. - 4. The $2<sup>nd</sup>$ respondent also opposed the petition and pleaded that it does not raise any matters for constitutional interpretation in terms of Article 137 of the Constitution.

Representation.

5. The petitioner was represented by Ms. Elizabeth Yaledi. The second respondent was represented by Mr. Bichachi Ojambo (State Attorney), while the $1^{st}$ and $3^{rd}$ respondents were represented by Mr. Martin Kakuru.

$18078$

Considerations.

d

- 6. When the petition came up for hearing on 18th November 202\$, the court noted that the 2nd respondent was wrongly added as a party to the petition. It was also noted that the Attorney General had not been added as a party to the petition. The court therefore struck out the 2nd respondent and granted leave to the petitioner to amend the petition by adding the Attorney General p <sup>a</sup> party. - 7. The court also directed the petitioner to file and serve the petition by 25th November 2024. The respondents were given up to 9th December 2024 to file and serve their responses to the petition. A rejoinder if any, was to be filed by 13th December 2024. Directions were given to the Court . Registrar to conduct a scheduling conference. The court reserved its - 8. The directions to the parties have to date not been adhered to. This amounts to failure to prosecute the petition. - 9. The petition therefore stands dismissed for want of prosecution, with no orders as to costs. N

v,

\Y..

Dated at Kampala this ....................................

Geoffrey Kiryabwire

Justice of the Constitutional Court.

Mamincilee 2.

Muzamiru M. Kibeedi

Justice of the Constitutional Court.

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Christopher Gashirabake

Justice of the Constitutional Court.

Oscar John Kihika.

Justice of the Constitutional Court.

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Margaret Tibulya Justice of the Constitutional Court.

Source wording is retained. Consult the source document for its original formatting and pagination.

Authorities

Authorities used by the court

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

Constitution of Uganda, Article 137

Legislation

Legislation referenced in the available case record.

Constitutional Court (Petitions and References) Rules, 2005

Legislation

Legislation referenced in the available case record.

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