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Uganda Judgment

High Court of Uganda

Uganda v Asiimwe (Civil Appeal 31 of 2023) [2024] UGHC 853 (29 August 2024)

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Professional case brief

Research organized from the available case record

Source document

01

Holding and result

The appeal was incurably defective because it was filed and signed by the complainant, who lacked statutory authority to do so in a criminal matter prosecuted by the DPP. The law requires that such appeals be filed and signed by the DPP or a person authorized by the DPP. Furthermore, the DPP is only permitted to appeal against acquittals and not against sentences under the Magistrates Court Act. In the absence of any statutory provision allowing the complainant or the DPP to appeal against sentence in these circumstances, the court found the appeal unsustainable and dismissed it.

Court disposition

appeal dismissed

Orders

  • The appeal is dismissed.

02

Material facts

Parties

Uganda

Appellant

Asiimwe Shaban

Respondent

Amounts and remedies

  • Fine Imposed by Trial Court: UGX 200,000
  • Compensation Ordered by Trial Court: UGX 100,000

03

Procedural history

  1. Posture

    Criminal Appeal / Judgment

04

Questions and positions

Legal issues

Party arguments

Applicant
The complainant, dissatisfied with the sentence and compensation awarded by the trial magistrate, sought to appeal the decision, but did not file a memorandum of appeal or obtain express permission from the DPP to file the notice of appeal.
Respondent
The respondent did not file a formal response, but the court considered the procedural irregularity of the appeal being filed by the complainant rather than the DPP, and the lack of statutory authority for such an appeal.

05

Court’s reasoning

  1. 01

    Section 204(5) of the Magistrates Court Act Cap. 19

    The right to appeal in criminal matters is statutory and must be exercised in accordance with the law.

  2. 02

    Section 54 of the Criminal Procedure Code Act Cap. 122

    Where an appeal is made by the DPP, the notice must be signed by the DPP or an authorized person.

06

Ratio, limits and disposition

Ratio decidendi

The appeal was incurably defective because it was filed and signed by the complainant, who lacked statutory authority to do so in a criminal matter prosecuted by the DPP. The law requires that such appeals be filed and signed by the DPP or a person authorized by the DPP. Furthermore, the DPP is only permitted to appeal against acquittals and not against sentences under the Magistrates Court Act. In the absence of any statutory provision allowing the complainant or the DPP to appeal against sentence in these circumstances, the court found the appeal unsustainable and dismissed it.

Obiter and limits

  • The right to appeal is a creature of statute and cannot be exercised outside the express provisions of the law.
  • No express permission was given to the complainant to file and sign the notice of appeal on behalf of the DPP.

Court disposition

appeal dismissed

  • The appeal is dismissed.

Source and reliance status

High Court of Uganda

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Source document

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Judgment text

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Source document

High Court of Uganda

Judgment

[2024] UGHC 853

THE REPUBLIC OF UGANDA IN THE HIGH COURT OF UGANDA AT FORT PORTAL CRIMINAL APPEAL NO. 031 OF 2023 (ARISING KMG-00-CR-CO-30-2019)

UGANDA ::::::::::::::::::::::::::: APPELLANT

VERSUS

ASIIMWE SHABAN :::::::::::::::::::::: RESPONDENT

BEFORE HON. MR. JUSTICE VINCENT EMMY MUGABO

JUDGMENT

This is an appeal against the judgment and orders of H/W Kirya Martins, the then Magistrate Grade 1 of the Chief Magistrate's Court of Kamwenge, delivered on the 24th of May 2019, wherein the respondent was found guilty of the offence of assault occasioning bodily harm, sentenced to a fine of UGX. 200,000, and ordered to pay compensation of UGX 100,000 to the complainant.

Background

The respondent was charged with the offence of assault occasioning bodily harm, contrary to section 236 (now section 219) of the Penal Code Act Cap.

128. It is alleged that on the 23rd day of December 2019, at Busingye Trading Centre, Bukonderwa Cell, Kitonzi Ward in Kamwenge District, the respondent unlawfully assaulted Bakundakabo Pauline, thereby causing her actual bodily harm.

The trial magistrate found the respondent guilty as charged and sentenced him to a fine of UGX. 200,000. The trial court also ordered the respondent to pay compensation of UGX. 100,000 to the complainant.

Being dissatisfied with the orders of the trial magistrate, the complainant filed this appeal. No memorandum of appeal was filed stating the grounds or particulars of the matters of law or fact the court appealed from is alleged to have erred.

The decision of the Court

I take note of the fact that criminal proceedings against the respondent were instituted by the Director of Public Prosecutions (DPP) who should have filed and signed the notice of appeal.

Section 54 of the Criminal Procedure Code Act Cap. 122 is to the effect that where an appeal or an application for revision is made by the DPP, the notice or application, as the case may be, shall be signed by him or her or by such other person as he or she may authorize either generally or specifically for that purpose.

There is no express permission that was given to the complaint to file and sign the notice of appeal on behalf of the DPP. In the absence of any expression permission to the complainant to sign the notice of appeal, I find this appeal to have been irregularly filed.

Be that as it may, the respondent herein was convicted, and the only probable appeal would be against the sentence. Never mind that no grounds of appeal were filed to show this court which particulars of the matters of law or fact, the court appealed from is alleged to have erred.

Interestingly, the DPP is allowed to appeal against an acquittal and not sentence *(see: section 204(5) of the Magistrates Court Act Cap. 19).*

It is trite that the right to appeal is a creature of the statute and in the absence of any statutory provision of the law allowing the DPP to appeal against the sentence, this appeal cannot be sustained.

Resultantly, I find this appeal to be incurably defective and it is hereby dismissed.

It is so ordered.

Dated at Fort Portal this 29th day of August 2024.

Vincent Emmy Mugabo Judge

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Authorities

Authorities used by the court

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

Section 236 (now section 219) of the Penal Code Act Cap. 128

Legislation

Legislation referenced in the available case record.

Section 54 of the Criminal Procedure Code Act Cap. 122

Legislation

Legislation referenced in the available case record.

Section 204(5) of the Magistrates Court Act Cap. 19

Legislation

Legislation referenced in the available case record.

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