Dr. Kabiito Richard v Makerere University and Others (Miscellaneous Cause 184 of 2020)
Observed later treatment
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Holding
Held that an application for judicial review challenging a preliminary investigative letter requesting written response to sexual harassment allegations is not amenable to judicial review where no final administrative decision has been made, the applicant has not exhausted internal remedies, and the matter concerns private rights requiring determination of factual guilt rather than review of decision-making process. Application dismissed.
Outcome
Application dismissed for lack of amenability to judicial review
Facts
Dr. Kabiito Richard, a lecturer at Makerere University, was notified by letter dated 5 February 2020 that a sexual harassment complaint had been lodged against him by a female undergraduate student. The letter requested a written response within seven days as part of preliminary investigations by the Vice Chancellor's Ad Hoc Committee. Dr. Kabiito filed this judicial review application seeking declarations that the investigative process violated his constitutional rights to fair hearing, that the university's sexual harassment policy was ultra vires, and seeking orders of certiorari, mandamus, prohibition, and damages. The university deposed that the investigation was in preliminary stages and had not progressed to a hearing or decision due to COVID-19 lockdown and the filing of these proceedings. No final administrative decision had been rendered and internal appeal mechanisms remained available.
Issues
- Whether the application is amenable to judicial review
Orders
- Application dismissed with costs to the respondents
Rules and key headnotes
Legislation cited (7)
- Constitution of Uganda Article 42
- Constitution of Uganda Article 50
- Constitution of Uganda Article 28
- Constitution of Uganda Article 44(c)
- Judicature Act s.33
- Judicature Act s.36
- Universities & Other Tertiary Institutions Act 2001 s.57(5)
Cases cited (4)
- Byaruhanga John Patrick v Commissioner for Land Registration (Miscellaneous Cause No. 235 of 2024)
- Chief Constable of North Wales Police v Heavens [1982] 3 All ER 108
- Uganda Association of Consulting Engineers Limited v The Prime Minister of the Republic of Uganda and 2 Others (Miscellaneous Cause No. 182 of 2024)
- Bwengye v Electoral Commission (Miscellaneous Cause No. 352 of 2021)
Cases citing this judgment (1)
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
The original judgment as reported. Read the original PDF before relying on any passage.