Buregyeya & Another v Arinatwe (Civil Appeal 36 of 2020)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that taxation of costs is governed by the law in force at the time judgment was delivered, not when the bill is filed for taxation. The suit was filed in 2012 and judgment delivered in 2014, therefore the applicable law was the Advocates (Remuneration and Taxation of Costs) Rules 1996. The 2018 regulations contain no saving provisions and statutes do not operate retrospectively unless expressly stated. The taxing master erred in deploying a hybrid approach combining both old and new rules. Award set aside and matter remitted for retaxation under the 1996 rules.
Outcome
Award of UgX 7,887,600/= set aside; matter remitted to a different taxing master for retaxation under the 1996 rules
Facts
The plaintiffs filed Civil Suit No. 86 of 2012 on 15 March 2012 against the defendants. Judgment was delivered on 24 September 2014 in favour of the plaintiffs. The plaintiffs filed their bill of costs for taxation on 1 October 2019. The taxing master, faced with a bill drawn under the 2018 taxation rules, adopted a hybrid approach combining the old 1996 rules and the new 2018 rules to avoid what he perceived as injustice to the judgment debtor. He taxed the bill at UgX 7,887,600. The plaintiffs appealed, arguing that the taxing master erred by failing to apply the 2018 rules which had replaced the 1996 rules. The respondent did not file a reply to the appeal.
Issues
- Whether the taxing officer erred in law and fact when he failed to properly apply known principles of taxation.
- Whether the bill of costs should be taxed under the Advocates (Remuneration and Taxation of Costs) Rules 1996 or the Advocates (Remuneration and Taxation of Costs) Regulations 2018.
- Whether the taxing officer's hybrid approach to taxation was proper in law.
Orders
- The award of UgX 7,887,600/= is hereby set aside.
- An order is hereby issued that the bill in Civil Suit No. 0086 of 2012 be retaxed before a different Taxing Master.
- Each party shall bear their own costs.
Rules and key headnotes
Legislation cited (5)
- Advocates Act s.62(1)
- Advocates (Taxation of Costs) (Appeals and References) Regulations SI 1267-5 r.2(a)
- Advocates (Taxation of Costs) (Appeals and References) Regulations SI 1267-5 r.3(c)
- Advocates (Remuneration and Taxation of Costs) Rules SI No. 3 of 1996
- Advocates (Remuneration and Taxation of Costs) Regulations SI No. 7 of 2018
Cases cited (4)
- Bank of Uganda v Banco Arabe Espanal (SC Civil Application No. 23 of 1999)
- Commissioner General Uganda Revenue Authority v Edulink Holdings Ltd and 2 Others (HCCA No. 178 of 2021)
- Mayanja Joshua and 70 Others v Wante Samuel and 60 Others (HCCS No. 497 of 2018)
- Uganda Bankers (Employers Association) v National Union of Clerical Commercial Professionals and Technical Employees (CACA No. 51 of 1996)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.