Ajupo Esther v Uganda (Criminal Appeal 216 of 2022)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The Court of Appeal, re-evaluating the evidence on a first appeal, upheld the murder conviction grounded on circumstantial evidence, holding that the inculpatory facts (the appellant alone with the deceased, her failure to raise an alarm, her false assurance to neighbours, and her attempt to conceal the death) were incompatible with her innocence and incapable of any reasonable explanation other than guilt; PW8's key evidence was direct, not hearsay, and the absence of DNA, fingerprint or defensive-injury evidence did not prejudice the case. On sentence, the trial judge had considered all mitigation placed before him, and new mitigation not raised at trial was no ground for interference. The appeal was dismissed and the conviction and sentence upheld.
Outcome
Conviction for murder and sentence of 25 years and 7 months' imprisonment upheld; appeal dismissed
Facts
On 25 August 2020 at Kiwatule Central Zone, Kampala, the appellant visited the deceased, Masembe Ian, who was her boyfriend. During the night a neighbour (PW8) heard a groaning sound from the deceased's house that went on for about an hour. PW8, with her landlady and another neighbour, went to the appellant's gate and found her standing by the tap speaking on a phone; when asked what the problem was she said there was none, and only on further probing said the deceased had killed himself. The matter was reported and police found the deceased's body on the bathroom floor in a pool of blood with about ten stab wounds; a postmortem gave the cause of death as haemorrhagic shock from loss of blood. The appellant claimed the deceased had stabbed himself while she remained in the kitchen, but did not raise an alarm. A government analyst found the blood on the knife and at the scene belonged to the deceased; no fingerprint or DNA evidence linked the appellant, and her clothes bore no blood stains. The appellant was convicted of murder.
Issues
- Whether the trial judge erred in failing to evaluate the whole evidence on record regarding the ingredient of participation when convicting the appellant, where the prosecution case rested on circumstantial and allegedly hearsay evidence.
- Whether the sentence of 25 years and 7 months' imprisonment was excessive in the circumstances and imposed without sufficient consideration of mitigating factors.
Orders
- The appeal fails on all grounds and is dismissed.
- The conviction and sentence of the lower court are upheld.
Rules and key headnotes
Legislation cited (4)
- Constitution of Uganda art.34(1)
- Children Act s.3(1)
- Children Act s.4(1)
- African Charter on the Rights and Welfare of the Child art.30(a)
Cases cited (6)
- Kifamunte Henry v Uganda (Criminal Appeal No. 10 of 1997)
- Mulindwa James v Uganda
- Simon Musoke v R [1958] 715
- Godi v Uganda
- Kiwalabye Bernard v Uganda (Criminal Appeal No. 143 of 2001)
- Bashir Ssali v Uganda
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.