Alijeda Ltd v Motiv Creations (U) Limited (Miscellaneous Application No. 2176 of 2025)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The court held that counsel's negligence in failing to appear for hearing cannot be visited upon a vigilant litigant. Where the applicant filed the application timeously and followed up diligently, the dismissal order should be set aside in the interest of justice under Section 98 of the Civil Procedure Act, notwithstanding counsel's failure to receive or respond to ECCMIS notifications.
Outcome
Application granted; earlier dismissal order set aside; default judgment and decree set aside; matter reinstated for hearing interparty
Facts
The applicant filed Miscellaneous Application No. 924 of 2025 on 2 May 2025 seeking leave to appear and defend Civil Suit No. 290 of 2025. The application was fixed for hearing on 3 July 2025 following the respondent's request on 11 June 2025. The applicant and its counsel did not appear on 3 July 2025 or on the adjourned date of 9 July 2025, resulting in dismissal of the application. The applicant contended it never received summons, notices or ECCMIS notifications despite diligent follow-up. A default judgment was subsequently entered in the underlying civil suit, followed by taxation and execution proceedings. The applicant then brought this application to set aside the dismissal order and consequential default judgment.
Issues
- Whether there is sufficient cause to set aside the dismissal order in Miscellaneous Application No. 924 of 2025?
- What remedies are available to the parties?
Orders
- Miscellaneous Application No. 924 of 2025 is hereby reinstated for hearing interparty and the order dismissing the same is set aside.
- The default judgment and decree issued vide Civil Suit No. 290 of 2025 is set aside.
- Taxation Application No. 437 of 2025 and Execution Miscellaneous Application No. 466 of 2025 arising therefrom are set aside.
- Costs of this application shall be in the cause.
Rules and key headnotes
Legislation cited (11)
- Civil Procedure Act Cap. 282 s.98
- Civil Procedure Rules SI 71-1 Order 9 rule 22
- Civil Procedure Rules SI 71-1 Order 9 rule 23
- Civil Procedure Rules SI 71-1 Order 9 rule 27
- Civil Procedure Rules SI 71-1 Order 36 rule 11
- Civil Procedure Rules SI 71-1 Order 52 rule 1
- Civil Procedure Rules SI 71-1 Order 52 rule 3
- Civil Procedure Rules SI 71-1 Order 6 rule 28
- Civil Procedure Rules SI 71-1 Order 19 rule 3(1)
- Civil Procedure Rules SI 71-1 Order 8 rule 1(2)
- Judicature (Electronic Filing, Service and Virtual Proceedings) Rules 2025
Cases cited (12)
- Uganda Telecom Ltd v ZTE Corporation (Supreme Court Civil Appeal No. 3 of 2017)
- Namutebi Matilda v Ssemanda Simon and 2 Others (Miscellaneous Application No. 430 of 2021)
- Bankone Limited v Simbamanyo Estates Limited (High Court Miscellaneous Application No. 645 of 2020)
- Male H.K Mabirizi v Attorney General (High Court Miscellaneous Application No. 89 of 2022)
- Florence Nabatanzi v Naome Binsobedde (Supreme Court Civil Application No. 6 of 1987)
- Sipiriya Kyarulesire v Justine Bakanchulike Bagambe (Supreme Court Civil Appeal No. 20 of 1995)
- Gideon Mose Onchwati Vs Kenya Oil Co. Ltd and Another [2017] eKLR
- Parimal Vs Veena Alias Bhati [2011] 3 SCC 545
- Nicholas Roussos v Gulam Hussein Habib Virani & Another (Supreme Court Civil Appeal No. 9 of 1993)
- Attorney General v AKPM Lutaaya (Supreme Court Civil Appeal No. 12 of 2007)
- Godfrey Magezi and Brian Mbazira v Sudhir Ruparelia (Supreme Court Civil Application No. 10 of 2002)
- Dr. Lam Lagoro James v Muni University (High Court Miscellaneous Cause No. 07 of 2016)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.