Bwowe Ivan v Electoral Commission and Others (Pre-Election Petition Appeal No. 5 of 2025)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that the failure by candidates to fill in the correct name of the constituency (Nakawa West instead of Nakawa Division West) was a minor irregularity or misnomer curable by the Electoral Commission under section 15 of the Electoral Commission Act and section 29(2) of the Parliamentary Elections Act. The control form signed by all candidates correctly identified the constituency as Nakawa Division West. Substantive justice requires that candidates not be disqualified on account of clerical errors that can be and were corrected. Petition dismissed.
Outcome
Petition dismissed; Electoral Commission decision upholding nominations affirmed
Facts
The Petitioner and the 2nd-8th Respondents were nominated by the Electoral Commission to contest for Member of Parliament for Nakawa Division West Constituency. The 2nd-8th Respondents filled their nomination forms stating the constituency as 'Nakawa West' instead of 'Nakawa Division West'. The Petitioner lodged a complaint with the Electoral Commission alleging that the 2nd-8th Respondents were nominated for a non-existent constituency. After a hearing, the Electoral Commission dismissed the complaint, finding that the control form signed by all candidates correctly identified the constituency as Nakawa Division West, that all candidates intended to campaign in the same geographical area, and that the error had been corrected. The Petitioner appealed to the High Court seeking to have the nominations of the 2nd-8th Respondents nullified and to be declared the only validly nominated candidate.
Issues
- Whether the Electoral Commission validly upheld the decision of the Returning Officer in nominating the 2nd-8th Respondents.
- What remedies are available.
Orders
- Petition dismissed.
- Electoral Commission's decision upholding the nomination of the 2nd-8th Respondents is upheld.
- Each party to meet their own costs.
Rules and key headnotes
Legislation cited (37)
- Constitution of Uganda 1995 Article 63
- Constitution of Uganda 1995 Article 61(1)(l)
- Constitution of Uganda 1995 Article 126(2)(e)
- Electoral Commission Act Cap. 176 s.71
- Electoral Commission Act Cap. 176 s.75(1)
- Electoral Commission Act Cap. 176 s.75(2)
- Electoral Commission Act Cap. 176 s.75(3)
- Electoral Commission Act Cap. 176 s.75(4)
- Electoral Commission Act Cap. 176 s.75(5)
- Electoral Commission Act Cap. 176 s.8(8)
- Electoral Commission Act Cap. 176 s.12(1)(e)
- Electoral Commission Act Cap. 176 s.12(1)(f)
- Electoral Commission Act Cap. 176 s.15(1)
- Electoral Commission Act Cap. 176 s.49(1)
- Electoral Commission Act Cap. 176 s.49(2)
- Parliamentary Elections Act Cap. 777 s.26
- Parliamentary Elections Act Cap. 777 s.27
- Parliamentary Elections Act Cap. 777 s.28
- Parliamentary Elections Act Cap. 777 s.28(1)
- Parliamentary Elections Act Cap. 777 s.29
- Parliamentary Elections Act Cap. 777 s.29(2)
- Parliamentary Elections Act Cap. 777 s.29(2)(a)
- Parliamentary Elections Act Cap. 777 s.29(2)(b)
- Parliamentary Elections Act Cap. 777 s.29(2)(c)
- Parliamentary Elections Act Cap. 777 s.29(3)(i)
- Parliamentary Elections Act Cap. 777 s.29(3)(ii)
- Parliamentary Elections Act Cap. 777 s.29(3)(iii)
- Parliamentary Elections Act Cap. 777 s.30
- Parliamentary Elections Act Cap. 777 s.31
- Parliamentary Elections Act Cap. 777 s.32
- Parliamentary Elections Act Cap. 777 s.33
- Parliamentary Elections Act Cap. 777 s.37
- Parliamentary Elections (Appeals to the High Court from Commission) Rules SI 141-1 Rule 4
- Parliamentary Elections (Appeals to the High Court from Commission) Rules SI 141-1 Rule 5
- Parliamentary Elections (Appeals to the High Court from Commission) Rules SI 141-1 Rule 7(1)
- Parliamentary Elections (Appeals to the High Court from Commission) Rules SI 141-1 Rule 8(4)
- Parliamentary Elections (Appeals to the High Court from Commission) Rules SI 141-1 Rule 15(1)
Cases cited (6)
- Abdulrahman Elamin v Dhabi Group and 2 Others (Civil Suit No. 432 of 2012)
- Sanyu Sarah v China Railway Group and Uganda National Roads Authority (Civil Suit No. 11 of 2024)
- Okobe Patrick v Opio Joseph Linos and Another (Election Petition No. 87 of 2016)
- Winifred Komuhangi Mosiko v Bomukwotso Belty aka Muzoniro Betty and Electoral Commission (Election Petition No. 4 of 2018)
- Toolit Aketcho v Oulonya Jacob L'okori and Another (High Court Election Petition No. 1 of 2016)
- Kosongaki Diana v Fulgensia Tumwesigye (Civil Application No. 21 of 2023)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.