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Uganda Judgment

HC: Criminal Division (Uganda)

Uganda v Ekwere & Anor (HCT-09-CR-SC-0062 of 2016) [2017] UGHCCRD 85 (28 April 2017)

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Source document

01

Holding and result

The court found that, in the absence of a post mortem or medical report, there was no evidence to establish the cause of death of Emorut Andrew. Without proof that the accused's actions led to the death, the prosecution failed to establish a prima-facie case of murder against the accused. The court held that the accused had no case to answer and acquitted them of the charges.

Court disposition

acquitted

Orders

  • The accused are acquitted of the charge of murder and set free.

02

Material facts

Parties

Uganda

Applicant

Ekwere Simon Peter

Defendant

Acam Florence Betty alias Akia

Defendant

03

Procedural history

  1. Posture

    Criminal Law / Ruling on No Case to Answer

04

Questions and positions

Legal issues

Party arguments

Applicant
The prosecution alleged that the accused assaulted the deceased, Emorut Andrew, and that their actions led to his death. The prosecution relied on witness testimony regarding the assault and the subsequent death of the deceased.
Respondent
The accused denied causing the death of Emorut Andrew. They argued that there was no medical or post mortem report establishing the cause of death, and that the prosecution failed to link their actions to the death.

05

Court’s reasoning

  1. 01

    Penal Code Act, Sections 188 and 189

    The prosecution must prove beyond reasonable doubt that the accused caused the death of the deceased.

  2. 02

    Ugandan criminal jurisprudence

    In the absence of medical evidence establishing cause of death, the court cannot infer causation from circumstantial evidence alone.

06

Ratio, limits and disposition

Ratio decidendi

The court found that, in the absence of a post mortem or medical report, there was no evidence to establish the cause of death of Emorut Andrew. Without proof that the accused's actions led to the death, the prosecution failed to establish a prima-facie case of murder against the accused. The court held that the accused had no case to answer and acquitted them of the charges.

Court disposition

acquitted

  • The accused are acquitted of the charge of murder and set free.

Source and reliance status

HC: Criminal Division (Uganda)

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Source document

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Judgment text

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Source document

HC: Criminal Division (Uganda)

Judgment

[2017] UGHCCRD 85

THE REPUBLIC OF UGANDA

IN THE HICH COURT OF UGANDA

HOLDEN AT SOROTI

HCT-09-CR-SC-0062 OF 2016

UGANDA::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::PROSECUTION

*VERSUS*

EKWERE SIMON PETER & ANOTHER:::::::::::::::::::::ACCUSED

BEFORE HIS LORDHIP HON. MR. JUSTICE BATEMA N. D. A, JUDGE

Ruling

This is a matter where the two accused were charged with Murder C/S 188 and 189 of the Penal Code Act. It was alleged that Ekwere Simon Peter and Acam Florence Betty alias Akia on the 11th day of July 2011 at Kamacha in the Bukedea district murdered Emorut Andrew.

The evidence adduced in Court shows that the deceased Emorut was an orphan suffering from epilepsy. He often would fall down with attacks of epilepsy. He was involved in two violent fights before his death but did not get proper medical care.

At one time he was badly beaten at a disco event. The last is when he had a fight with the two accused relatives. Both accused assaulted him on the hand using a stick used to drive oxen.

On 14/8/2011, a month later, the deceased fell sick and died.

In the absence of a post mortem or medical report to tell us the cause of death, this Court is unable to conclude that it is the acts of the accused that caused Emorut’s death.

Prosecution has failed to establish any prima-facie case against the accused to require them to be put on their defence.

The accused have no case to answer on these charges of Murder. They are both acquitted and set free.

Judge

28/4/2017

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Authorities

Authorities used by the court

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

Penal Code Act, Sections 188 and 189

Legislation

Legislation referenced in the available case record.

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