A1 Car Hire Services Ltd v James Nyanzi and Another (Miscellaneous Application 1095 of 2020)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The court held that the judgment sought to be set aside was not an ex parte judgment within the meaning of Order 9 rule 27 of the Civil Procedure Rules. The applicant had been duly served, filed a defence, participated in scheduling, gave evidence, and was cross-examined. His failure to file written submissions by the deadline did not render the judgment ex parte. The application was wrongly brought under Order 36 rule 3(1) which governs summary procedure. The court dismissed the application with costs.
Outcome
Application to set aside judgment dismissed
Facts
A1 Car Hire Services Ltd filed a suit in 2011 against James Nyanzi and Chris Kakembo claiming return of a motor vehicle valued at UGX 24,840,000 allegedly obtained through fraud and conversion. Both defendants filed written statements of defence. The matter proceeded through multiple judges over ten years. On 3 February 2020, the trial judge directed parties to file written submissions with the defendants' deadline being 2 March 2020. The plaintiff filed in time but Kakembo did not. Judgment was delivered on 18 May 2020. Kakembo filed his submissions on 19 August 2020, three months after judgment. On 4 December 2020, Kakembo applied to set aside the judgment claiming it was ex parte and that he only discovered it had been delivered on 3 September 2020 during the COVID-19 lockdown.
Issues
- Whether the application and supporting affidavit are incurably defective and constitute an abuse of court process.
- Whether the judgment in HCCS No. 0077 of 2017 was an ex parte judgment within the meaning of Order 9 rule 27 of the Civil Procedure Rules.
- Whether the applicant satisfied the requirements for setting aside the judgment under Order 9 rule 27 of the Civil Procedure Rules.
Orders
- Application dismissed.
- Costs awarded to A1 Car Hire Services Ltd.
Rules and key headnotes
Legislation cited (10)
- Civil Procedure Act s.98
- Judicature Act s.33
- Civil Procedure Rules Order 9 rule 27
- Civil Procedure Rules Order 9 rule 28
- Civil Procedure Rules Order 9 rule 29
- Civil Procedure Rules Order 36 rule 3(1)
- Civil Procedure Rules Order 9 rule 11
- Civil Procedure Rules Order 9 rule 20(a)
- Civil Procedure Rules Order 17 rule 4
- Constitution of Uganda Article 126(2)(e)
Cases cited (2)
- Dr. Peter Musoke Gukina v Speke Hotel and Others (Miscellaneous Application No. 239 of 2019)
- Baluku Zaverio and Another v Mukanirwa Joel & 10 Others (High Court Civil Suit No. 25 of 2016)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.