Center For Health, Human Rights and Development (CEHURD) and Others v Uganda National Health Research Organization (UNHRO) and Others (Miscellaneous Application 439 of 2019)
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Holding
The High Court dismissed the application on procedural grounds, striking out the applicants' supporting affidavits for containing inadmissible hearsay evidence and statements not within the deponents' personal knowledge. The court found that after expunging the offending paragraphs which contained medical and factual assertions without source, the remaining paragraphs could not support the application. The court did not reach the substantive constitutional issues raised. Costs were awarded to the respondents.
Outcome
Application dismissed on procedural grounds for defective affidavits; substantive constitutional claims not determined
Facts
The applicants, three health rights advocacy organizations, challenged a clinical trial known as the Children's Oxygen Administration Strategies Trial (COAST) which was conducted on children aged 28 days to 12 years with hypoxia at multiple hospitals. The trial was approved by the respondents in 2016 and started in 2017, sponsored by Imperial College London. The applicants alleged that during the trial, study participants were randomly assigned to different oxygen delivery strategies including permissive hypoxia and low flow oxygen below recommended standards, that several children died, that appropriate care was not provided for life-threatening diagnoses beyond hypoxia, and that the trial proceeded without proper regulatory approval. The trial was halted in 2018 following concerns raised by a committee of intensivists but was later restarted. The applicants sought declarations that the trial violated constitutional rights to health and life, and a permanent injunction stopping the trial.
Issues
- Whether the approval and clearance of the COAST protocol by the 1st and 2nd Respondents without ascertaining that it caters for the care needed for critically ill patients is a violation of the right to health and a threat to the right to life.
- Whether the clearance, approval and conduct of the COAST by the Respondents without adherence to responsibilities of health professionals on care and treatment of study participants is a violation of their obligation to respect and protect the rights of children, the right to dignity, freedom from cruel, inhuman and degrading treatment and a threat to the right to life.
- Whether failure of the 3rd Respondent to obtain a certificate of approval from National Drug Authority prior to conducting the COAST study is a violation of the right to health and a threat to the right to life.
- Who is responsible for approval of clinical trials in Uganda.
- Whether the Applicants are entitled to the remedies sought.
Orders
- Preliminary objection that the matter is moot overruled.
- Offending paragraphs in the affidavits in support of the application struck out for containing hearsay and statements not within the deponents' personal knowledge.
- Application dismissed.
- Costs awarded to the Respondents.
Rules and key headnotes
Legislation cited (14)
- Constitution of the Republic of Uganda 1995 Article 50(2)
- Constitution Article 22(1)
- Constitution Article 8A(1)
- Constitution Article 45
- Constitution Article 20
- Constitution Article 24
- Constitution Article 34(3)
- Constitution Article 34(7)
- Constitution Article 44(a)
- Judicature (Fundamental & Other Human Rights and Freedoms) (Enforcement Procedure) Rules Rule 7
- Civil Procedure Act s.98
- Civil Procedure Rules Order 19 Rule 3(1)
- Health Service Commission Act 2001
- National Drug Policy and Authority (Conduct of Clinical Trials) Regulations 2014
Cases cited (7)
- Kwesiga William and Others v Ssenyonga Haruna and 7 Others (Supreme Court Civil Appeal No. 43 of 2021)
- Julius Maganda v National Resistance Movement (High Court Miscellaneous Application No. 154 of 2010)
- Patricia Asero Ochieng & 2 Ors. -v- Attorney General, High Court of Kenya Petition No. 409 of 2019 (2012) eKLR
- Male Mabirizi v Attorney General (Supreme Court Civil Appeal No. 7 of 2018)
- Attorney General and Another v Human Rights Awareness and Promotion Forum (High Court Miscellaneous Application No. 482 of 2020)
- Retired Colonel Dr Kizza Besigye v Electoral Commission and Another (Presidential Petition No. 1 of 2001)
- Wambugu -v- Public Service Commission 1972 (E.A.) 296
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.