Amollo Rose and Another v Kyambogo University (Miscellaneous Cause 303 of 2023)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that the application for judicial review was premature because the applicants failed to exhaust available internal remedies and statutory appeal mechanisms before approaching the High Court. Under Rule 7A(1)(b) of the Judicature (Judicial Review) (Amendment) Rules 2019 and Section 57 of the Universities and Other Tertiary Institutions Act 2001, applicants must first appeal to the University Staff Tribunal before seeking judicial review. Judicial review is a remedy of last resort available only after exhausting alternative remedies. Application dismissed with costs.
Outcome
Application dismissed for prematurity — applicants failed to exhaust internal remedies
Facts
The applicants, employed by Kyambogo University for 17 and 26 years respectively as secretary and receptionist, were dismissed on 31 August 2023 by the University Council for gross misconduct. The dismissal followed allegations that they forged academic documents for one Nafula Judith, who allegedly paid them UGX 350,000. A whistleblower from the National Council for Higher Education reported the forgery in October 2021. The Academic Registrar investigated and Ms. Nafula Judith stated she received the certificate from Innocent Kisambira with the applicants' assistance. The matter was referred to the Appointments Board Disciplinary Committee, which heard evidence including telecommunication logs contradicting the applicants' denial of knowledge of Ms. Nafula. The applicants were charged under the University's Human Resource Manual and dismissed. They filed for judicial review seeking certiorari, mandamus, reinstatement, and damages, alleging procedural impropriety and bias.
Issues
- Whether this application is amenable to judicial review
Orders
- Application dismissed.
- Costs awarded to the respondent.
Rules and key headnotes
Legislation cited (24)
- Constitution of the Republic of Uganda Article 27
- Constitution of the Republic of Uganda Article 28(1)
- Constitution of the Republic of Uganda Article 42
- Constitution of the Republic of Uganda Article 44(c)
- Constitution of the Republic of Uganda Article 50(1)
- Constitution of the Republic of Uganda Article 173(b)
- Judicature Act Cap 13 s.33
- Judicature Act Cap 13 s.36
- Judicature Act Cap 16 s.36(1)
- Civil Procedure Act Cap 71 s.98
- Judicature (Judicial Review) Rules 2009 Rule 3
- Judicature (Judicial Review) Rules 2009 Rule 4
- Judicature (Judicial Review) Rules 2009 Rule 7
- Judicature (Judicial Review) Rules 2009 Rule 8
- Judicature (Judicial Review) (Amendment) Rules 2019 Rule 2(1)
- Judicature (Judicial Review) (Amendment) Rules 2019 Rule 7A
- Judicature (Judicial Review) (Amendment) Rules 2019 Rule 7A(1)(b)
- Civil Procedure Rules Order 52 Rule 2
- Universities and Other Tertiary Institutions Act 2001 s.2
- Universities and Other Tertiary Institutions Act 2001 s.22
- Universities and Other Tertiary Institutions Act 2001 s.57(1)
- Universities and Other Tertiary Institutions Act 2001 s.57(3)
- Kyambogo University Appointment Board Disciplinary Rules and Regulations 2017 Rule 16.0
- Kyambogo University Human Resource Manual Regulation 11.22.1(h)
Cases cited (4)
- Council of Civil Service Unions & Others v Minister for the Civil Service [1985] AC 374
- Uganda Association of Consulting Engineers v Attorney General (Miscellaneous Cause No. 182 of 2024)
- Byrahunga John Patrick v Commissioner for Land Registration (Miscellaneous Cause No. 235 of 2024)
- Sewanyana Jimmy v Kampala International University (HCMC No. 207 of 2016)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.