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Democratic Party and Another v Secretary General of East African Community and Another (Application 6 of 2011)

East African Court of Justice · [2012] EACJ 8 · 2012 Application Partly Allowed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Reference brought under the Treaty for the Establishment of the East African Community challenging Uganda's Rules of Procedure for election of members to the East African Legislative Assembly
Decision
Restraining order granted against Uganda's Parliament and Attorney General prohibiting EALA elections until Rules amended; case against 1st Respondent dismissed

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The Court held that Uganda's 2006 Rules of Procedure for electing members to the East African Legislative Assembly, which had been declared null and void by Uganda's Constitutional Court in 2008, remained unamended and did not conform to Article 50 of the Treaty for the Establishment of the East African Community. The Court restrained Uganda's Parliament and Attorney General from conducting EALA elections until the Rules are amended to conform to the Treaty. The Court found no failure by the Secretary General to supervise Uganda, as amendment processes were ongoing, but granted the restraining order to protect the Applicants' rights and ensure Treaty compliance.

Outcome

Restraining order granted against Uganda's Parliament and Attorney General prohibiting EALA elections until Rules amended; case against 1st Respondent dismissed

Facts

The Democratic Party and Mukasa Fred Mbidde challenged Uganda's Rules of Procedure for electing members to the East African Legislative Assembly. In 2008, Uganda's Constitutional Court in Jacob Oulanyah v Attorney General declared Rules 11(1) and Appendix B rules 3, 10, and 11 of the 2006 Parliamentary Rules null and void for contravening Uganda's Constitution and Article 50 of the EAC Treaty. The Attorney General obtained a stay of execution and appealed to the Supreme Court, where the appeal remained unheard. Despite the Constitutional Court's ruling, the Rules remained unamended four years later. The Applicants feared that upcoming EALA elections would be conducted under the invalid Rules, denying them representation. They sought declarations that the Rules contravened the Treaty and restraining orders against conducting elections until the Rules were amended. The Court granted a temporary injunction pending determination of the Reference.

Issues

  1. Whether the 1st Respondent (Secretary General of the East African Community) has failed to supervise the Government of the Republic of Uganda to ensure that its National Assembly amends its Rules of Procedure for election of members of the East African Legislative Assembly.
  2. Whether the Applicants are entitled to the declarations sought against the Respondents.

Orders

  • The Parliament of the Republic of Uganda, the Attorney General of the Republic of Uganda, and the EALA are restrained and prohibited from conducting and carrying out any elections of members to the EALA, assembling, convening, recognising, administering Oath of Office or otherwise howsoever presiding over or participating in the election of the Representatives of Uganda and recognising of any names of nominees as duly nominated and elected to the EALA until Rules 11(1) and Appendix B r 3, 10 and 11 of the Rules of Procedure of the Parliament of Uganda, 2006 are amended by the Parliament of the Republic of Uganda to conform to the provisions of Article 50 of the Treaty for the Establishment of the East African Community.
  • The case against the 1st Respondent is dismissed with no orders as to costs.
  • The 2nd Respondent shall pay the costs of this Reference to the Applicants.

Rules and key headnotes

Treaty Obligations — Domestic Implementation — Duty to Amend Non-Conforming Legislation
Where a Partner State's domestic legislation has been declared unconstitutional and inconsistent with Treaty provisions by its own courts, the Partner State has an obligation to amend such legislation to conform to the Treaty, and inordinate delay in doing so may justify judicial intervention to prevent Treaty violations.
Regional Legislative Assembly Elections — Treaty Requirements — Representation of Political Parties and Shades of Opinion
Article 50 of the Treaty for the Establishment of the East African Community requires that elections to the East African Legislative Assembly be conducted by National Assemblies in a manner that represents, as much as is feasible, the various political parties, shades of opinion, gender, and other special interest groups in the Partner State.
Declaratory Relief — Conditions for Grant — Real Practical Value
A court will not grant declaratory relief unless the remedy would be of real practical value to the applicant and will not grant declarations that are academic, hypothetical, or of no practical value.
Preliminary Objections — Mootness — Ongoing Amendment Processes
A reference is not moot, anticipatory, or premature where impugned rules remain law, efforts to amend them are not promising, an appeal against their nullification is still in place, and there is legitimate fear that elections may be conducted under the invalid rules to the applicant's disadvantage.
Secretary General's Supervisory Role — Duty to Follow Up on Treaty Violation Complaints
While the Secretary General of the East African Community cannot be faulted for failing to supervise a Partner State where amendment processes are ongoing, the Community Secretariat should establish a standard practice of following up on allegations of treaty infringements once it receives formal communication and providing feedback to complainants.
Separation of Powers — Judicial Restraint — Legislative Procedures
The East African Court of Justice will not interpret or give guidance to a Partner State's legislature on what constitutes compliance with Treaty provisions where the Treaty expressly provides that elections shall be conducted in accordance with such procedure as the National Assembly may determine, as this is the preserve of the National Assembly.

Legislation cited (28)

Cases cited (9)

  • Jacob Oulanyah v Attorney General (Constitutional Petition No. 28 of 2006)
  • Mukisa Biscuit Manufacturing Company Ltd v West End Distributors Ltd [1969] EA 696
  • Prof Peter Anyang Nyong'o and Others v Attorney General of Kenya and 2 Others (Reference No. 1 of 2006)
  • Christopher Mtikila v Attorney General of Tanzania and Secretary General of the East African Community (Reference No. 2 of 2007)
  • Cox v Green [1996] Ch 216
  • Loel v Sanger [1949] Ch 258
  • Mellstram v Garner [1970] 1 WLR 603
  • Bennet v Chappel [1966] Ch 391
  • Williams v Home Office (No. 2) [1981] 1 All ER 1211

Full judgment

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

Democratic Party and Another v Secretary General of East African Community and Another (Application 6 of 2011) [2012] EACJ 8 (10 May 2012)
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.