Birungi and 3 Others v Kusemererwa and 2 Others (Revision Application No. 1 of 2021)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that a party cannot opt for appeal and then later apply for review of the same decision. Review under section 82 of the Civil Procedure Act and Order 46 rule 1 of the Civil Procedure Rules is not available where an appeal has been preferred. An applicant who had evidence available at trial but failed to adduce it cannot obtain a retrial by seeking review; the proper course was to apply to adduce fresh evidence on appeal. The application was dismissed with no order as to costs given the familial relationship between the parties.
Outcome
Revision application dismissed; applicants remain bound by the earlier judgment in Civil Appeal No. 74 of 2014.
Facts
The applicants sought review of the judgment and orders in Civil Appeal No. 74 of 2014 arising from Civil Suit No. 73 of 2008, both concerning a land dispute. The applicants claimed that material evidence — specifically a certificate of title registered in January 2009 after the suit was filed, and a will — had not been adduced at trial due to their former counsel's omission. They argued this constituted a material irregularity warranting retrial. The third respondent opposed the application, stating that the certificate was registered after the suit was filed and could not be introduced at this stage, and that the applicants were attempting to introduce evidence not previously pleaded or exhibited. Civil Suit No. 73 of 2008 was originally filed in the Chief Magistrate's Court at Hoima; the applicants lost at trial and on appeal.
Issues
- Whether the court should review and set aside the judgment and orders in Civil Appeal No. 74 of 2014 and Civil Suit No. 73 of 2008 and order a fresh trial.
- Whether a party who has appealed a decision can subsequently apply for review of the same decision.
- Whether the applicants' failure to adduce certain evidence (certificate of title and will) at trial constitutes a sufficient ground for review.
Orders
- Application dismissed.
- No order as to costs.
Rules and key headnotes
Legislation cited (2)
- Civil Procedure Act s.82
- Civil Procedure Rules O.46 r.1(1)
Cases cited (5)
- Ahmada B. Zirondomu v Mary Kyamutabi (1975) 1 HCB 337
- National Insurance Corporation v Mugenyi & Co. Advocates (1987) HCB 28
- Uganda Taxi Operation & Drivers Association v Uganda Revenue Authority (SCCA No. 24 of 2019)
- Brown v Dean [1910] AC 373
- Hon. Bangirana Kawoya v National Council for Higher Education (Misc. Application No. 8 of 2013)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.