Wakilii

Byaruhanga v Okullu and Another (Civil Appeal No. 034 of 2008)

Court of Appeal · [2019] UGCA 2129 · 2019 Appeal Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Civil appeal from a High Court judgment enforcing a right of way over an access road
Decision
Appeal dismissed; trial court's declaration, injunction, alternative access order and award of general damages upheld

Observed later treatment

Cited — treatment unverified cited in 2 (treatment unverified) Sequitur — Uganda’s citator · Derived from citing cases in the Wakilii corpus — not an assertion that this case is good law.

Citator coverage is limited to judgments in the Wakilii corpus and source-matched treatment records. Absence of a signal is not an assertion that the case remains good law.

No adverse treatment recorded Cited 2 times with no adverse treatment recorded; not yet tested on the merits. Derived from citing cases in the Wakilii corpus — a deterministic signal, not legal advice.

AI-generated summary. This summary was generated by AI from the full text of the judgment. It may contain errors or omissions—always read the source judgment before relying on it.

Holding

The Court of Appeal dismissed the appeal, holding that there was a planned and surveyed access road created by the previous owner upon subdivision which the appellant had no right to block. The trial Judge had properly evaluated the evidence, including site and location plans and the appellant's own admission of blocking the road. The court upheld the trial Judge's order directing the appellant to provide an alternative route by way of compensation rather than unconditionally enforcing the original access, which would have required demolishing the appellant's school structure. The court declined to interfere with the award of general damages, finding it compensatory and not based on any wrong principle.

Outcome

Appeal dismissed; trial court's declaration, injunction, alternative access order and award of general damages upheld

Facts

A man named Tomusange originally owned a large parcel of land which he subdivided and sold to various individuals, including the parties. Upon subdivision, a residual strip (Plot 3994) was retained to serve as an access road connecting the respondents' plots to a public road leading to Namuwongo. Approved site and location plans (Exhibit P3) showed this access road. The appellant's amalgamated title (Plot 6073) cut off part of Plot 3994, and the appellant blocked the access road, partly with the permission of respondent no.2, and erected a school building and pit latrine over the planned access. The respondents complained to local authorities and obtained, then lost, permission to open the road after the appellant intervened. The respondents sued to enforce their right of way, claiming a declaration, injunction, general damages and interest. The trial Judge found the appellant had blocked the surveyed access road and ordered an alternative route by way of compensation, plus damages.

Issues

  1. Whether the trial Judge properly evaluated the evidence in finding that the appellant blocked a planned access road serving the respondents' plots.
  2. Whether the trial court erred in ordering the appellant to provide an alternative access route as a remedy.
  3. Whether an alternative existing road served the respondents such that no relief should have been granted.
  4. Whether the trial Judge erred in awarding general damages against the appellant.

Orders

  • Appeal dismissed with costs here and below.

Rules and key headnotes

Land & Property — Easements — Right of Way over Surveyed Access Road on Subdivision
Where a previous landowner, upon subdivision, retains a residual strip as a planned and surveyed access road serving the subdivided plots, a subsequent purchaser whose title cuts off that strip has no right to block the access road.
Land & Property — Remedies — Alternative Access Route by Way of Compensation
Where unconditionally enforcing an original right of way would require destroying structures erected by the wrongdoer, a court may, in the interests of justice, order the wrongdoer to provide an alternative access route by way of compensation rather than enforcing the precise original route.
Damages & Quantum — Appellate Interference with General Damages
An appellate court may not interfere with an award of general damages unless it is so inordinately high or low as to represent an entirely erroneous estimate, or it is shown that the trial Judge proceeded on a wrong principle or misapprehended the evidence; general damages are compensatory and aim to restore the injured party to the position obtaining before the wrong.

Legislation cited (1)

Cases citing this judgment (2)

How later Ugandan judgments in the Wakilii corpus have cited this case. Treatment labels come from Sequitur — Uganda’s citator — each backed by a verbatim span from the citing judgment, and are not an assertion that this case is, or is not, good law.

Full judgment

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

Byaruhanga v Okullu and Another (Civil Appeal No. 034 of 2008) [2019] UGCA 2129 (19 September 2019)
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.