Wakilii

Barozi and Another v Winyi (HCT-01-CV-MA 27 of 2003)

High Court · [2024] UGHC 749 · 2024 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for stay of execution of decree pending appeal to the Court of Appeal
Decision
Application for stay of execution dismissed; matter may proceed to appeal

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

An application for stay of execution pending appeal must demonstrate a serious and imminent threat of execution targeting the applicant's interests. The court dismissed the application where applicants had no developments on the disputed land and the respondent's efforts to enforce the decree against a third party did not constitute a threat to the applicants' interests. The mere lodging of an appeal and absence of delay are insufficient where substantial loss and visible threat of execution cannot be established.

Outcome

Application for stay of execution dismissed; matter may proceed to appeal

Facts

The applicants were unsuccessful defendants in Land Civil Suit No. 16 of 2013 decided on 13 October 2023. They lodged an appeal to the Court of Appeal and sought a stay of execution of the decree. The decree had directed them not to trespass on the suit land and ordered the 3rd defendant to grade the area. The respondent wrote to the 3rd defendant threatening contempt proceedings for non-compliance with the grading order. The applicants claimed this constituted a threat of execution that would destroy their livelihood from agriculture on the suit land. During the trial locus visit, the court had established that the applicants had no developments or activities on the suit land. The respondent opposed the stay application on grounds that the applicants were not on the land and the execution efforts were directed at the 3rd defendant, not the applicants.

Issues

  1. Whether the application meets the test for grant of stay of execution.
  2. What remedies are available in the circumstances?

Orders

  • Application dismissed forthwith.
  • Costs of the application granted to the Respondent but shall abide the outcome of the pending appeal in the Court of Appeal.

Rules and key headnotes

Stay of Execution — Test for Grant — Imminent Threat of Execution
For an application for stay of execution to succeed, the applicant must demonstrate a serious and imminent threat of execution which is visible and targets the interests of the person seeking the stay.
Stay of Execution — Requirements Under Order 43 Rule 4 CPR
An applicant for stay of execution must satisfy the court that: (a) substantial loss may result unless the order is made; (b) the application has been made without unreasonable delay; (c) security has been given for due performance of the decree; (d) an appeal has been lodged; and (e) there is a serious and imminent threat of execution.
Stay of Execution — Absence of Interest in Subject Matter
Where applicants have no developments on disputed land and are not in occupation thereof, they cannot demonstrate substantial loss or imminent threat of execution sufficient to warrant a stay, even where enforcement actions are being taken against a third party.

Legislation cited (6)

Cases cited (3)

  • Lawrence Musiitwa Kyazze v Eunice Busingye (Supreme Court Civil Application No. 18 of 1990)
  • Dr. Ahmed Muhammed Kisule v Greenland Bank (in Liquidation) (Supreme Court Civil Application No. 7 of 2010)
  • Kyambogo University v Prof. Isiah Omolo Ndiege (Court of Appeal Civil Application No. 341 of 2013)

Full judgment

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The original judgment as reported. Read the original PDF before relying on any passage.

Barozi and Another v Winyi (HCT-01-CV-MA 27 of 2003) [2024] UGHC 749 (16 August 2024)
Source: this page presents Wakilii’s issue analysis and metadata for a publicly reported Ugandan judgment. Any AI-generated summary is marked as such. Judgment text is sourced from the Uganda Legal Information Institute (ulii.org). Wakilii is not affiliated with ULII.