Akol Zipporah v Akol Hellen Odeke and Others (Miscellaneous Cause 198 of 2025)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The High Court lacks jurisdiction to hear and determine election complaints arising before and during polling as a court of first instance. Under Articles 61(1)(f) and 64(1) of the Constitution and Section 15 of the Electoral Commission Act, the Electoral Commission is the court of first instance for such complaints, with appeals lying to the High Court only after the Commission has made a final decision. The application was filed prematurely before the Electoral Commission completed its review process and was accordingly dismissed.
Outcome
Application dismissed for lack of jurisdiction and prematurity
Facts
The applicant sought judicial review seeking declarations that the first, second, and third respondents were not registered voters in their respective parishes following Parish Tribunal decisions in May 2025 ordering deletion of their names from the voters' roll. The applicant also sought orders prohibiting the Electoral Commission from nominating these respondents for the position of Woman Member of Parliament for Bukedea District in the January 2026 elections. The Electoral Commission had conducted a voter update period and public display of voter rolls. Objections were raised against the three respondents on grounds of lack of origin or residence in their registered parishes. Parish Tribunals recommended deletion of their names. The Electoral Commission invited the affected respondents to a review meeting on 2 October 2025, heard all parties, and upheld the tribunal decisions. The applicant filed the judicial review application before the Electoral Commission completed its review process.
Issues
- Whether the application for judicial review was properly before the High Court.
- Whether the High Court has jurisdiction to hear and determine election complaints arising before and during polling as a court of first instance.
- What remedies are available to the parties.
Orders
- Application dismissed.
- Each party to bear its own costs.
Rules and key headnotes
Legislation cited (33)
- Constitution of Uganda 1995 Article 42
- Constitution of Uganda 1995 Article 61(1)(e)
- Constitution of Uganda 1995 Article 61(1)(f)
- Constitution of Uganda 1995 Article 64(1)
- Constitution of Uganda 1995 Article 139(1)
- Constitution of Uganda 1995 Article 139(2)
- Electoral Commission Act Cap 175 s.12
- Electoral Commission Act Cap 175 s.14
- Electoral Commission Act Cap 175 s.15
- Electoral Commission Act Cap 175 s.26
- Electoral Commission Act Cap 175 s.26(1)
- Electoral Commission Act Cap 175 s.26(5)
- Electoral Commission Act Cap 175 s.26(8)
- Electoral Commission Act Cap 175 s.26(11)
- Electoral Commission Act Cap 175 s.26(12)
- Judicature Act Cap 16 s.37
- Judicature Act Cap 16 s.40(1)(b)
- Judicature Act Cap 16 s.40(1)(c)
- Judicature Act Cap 16 s.40(1)(d)
- Judicature Act Cap 16 s.40(2)
- Judicature Act Cap 16 s.40(3)
- Judicature Act Cap 16 s.40(5)
- Judicature Act Cap 16 s.40(6)
- Judicature Act Cap 16 s.40(7)
- Judicature (Judicial Review) Rules 2009 Rule 3(1)
- Judicature (Judicial Review) Rules 2009 Rule 3(2)
- Judicature (Judicial Review) Rules 2009 Rule 3(A)
- Judicature (Judicial Review) Rules 2009 Rule 4
- Judicature (Judicial Review) Rules 2009 Rule 6
- Judicature (Judicial Review) Rules 2009 Rule 7
- Judicature (Judicial Review) Rules 2009 Rule 8
- Civil Procedure Rules Order 6 Rule 1
- Civil Procedure Rules Order 6 Rule 5
Cases cited (3)
- Kizza Besigye v YK Museveni and Another (Election Petition No. 1 of 2001)
- Akol Hellen Odeke v Okodel Umar (Election Petition Appeal No. 6 of 2020)
- Akol Hellen Odeke v Okodel Umar (Supreme Court Civil Appeal No. 09 of 2021)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.