Wakilii

Ejulu v Itobu (HCMA 160 of 2022)

High Court · [2023] UGHCCD 124 · 2023 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for stay of execution pending appeal to the Court of Appeal
Decision
Application for stay of execution dismissed as premature

Observed later treatment

Cited — treatment unverified cited in 1 (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 1 time 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

Held that an application for stay of execution pending appeal must satisfy four conditions: filing of notice of appeal, substantial loss to the applicant if stay not granted, no unreasonable delay, and provision of security. The court found the application premature because the applicant had not yet responded to the notice to show cause why execution should not ensue under Order 22 rule 19. The applicant must first show cause at that stage before applying for stay of execution. Application dismissed with costs.

Outcome

Application for stay of execution dismissed as premature

Facts

The applicant filed an application for stay of execution of a decree in High Court Civil Appeal No. 76 of 2017 pending determination of his intended appeal to the Court of Appeal. The respondent had filed an application for execution (EMA No. 27 of 2022) seeking to execute costs of UGX 45,944,900 by arresting and detaining the applicant in civil prison. A notice to show cause why execution should not ensue was served on the applicant on 29 July 2022. The applicant filed this application on 11 November 2022 seeking stay of execution, arguing he would suffer irreparable loss and that his appeal had a high probability of success. The underlying dispute concerned land allegedly purchased by the applicant's father from Ali Nandi, which the appellate court found was an illegal transaction under the Land Transfer Act because Ali Nandi was a non-African without legal capacity to sell land in freehold tenure to Africans.

Issues

  1. Whether the applicant satisfied the conditions for grant of a stay of execution pending appeal to the Court of Appeal.

Orders

  • Application dismissed.
  • Costs awarded to the respondent.

Rules and key headnotes

Civil Procedure — Stay of Execution — Premature Application
Where a notice to show cause why execution should not ensue has been issued under Order 22 rule 19 of the Civil Procedure Rules, an application for stay of execution is premature before the applicant has responded to the notice and the court has considered any objections under Order 22 rule 20.
Civil Procedure — Stay of Execution — Conditions for Grant
An application for stay of execution pending appeal must satisfy four conditions: the applicant must show that a notice of appeal has been lodged; that substantial loss may result unless stay is granted; that the application has been made without unreasonable delay; and that security has been given for due performance of the decree.
Civil Procedure — Stay of Execution — Substantial Loss
The phrase 'substantial loss' does not represent any particular amount or size and cannot be qualified by any mathematical formula; it refers to any loss great or small of real worth or value as distinguished from a loss that is merely nominal.
Civil Procedure — Stay of Execution — Likelihood of Success
Where the underlying transaction on which the applicant's claim is based has been found to be illegal, and an illegality once brought to the attention of a court cannot be condoned, the applicant cannot demonstrate a likelihood of success in the appeal sufficient to warrant a stay of execution.

Legislation cited (7)

Cases cited (8)

  • Singh v Runda Coffee Estates Ltd [1966] EA
  • Lawrence Musiitwa Kyazze v Eunice Busingye (SCCA No. 18 of 1990)
  • Theodore Ssekikubo and Others v Attorney General and Others (Constitutional Application No. 3 of 2014)
  • Tropical Commodities Supplies Ltd and 2 Others v International Credit Bank Ltd (In Liquidation) [2004] 2 EA 331
  • GAPCO Uganda Ltd v Kaweesa and Another (MA No. 259 of 2013)
  • Kawalya Kaggwa v Registrar of Titles [1974] EA 48
  • Makula International Ltd v His Eminence Cardinal Nsubuga and Another [1982] HCB 11
  • John Baptista Kawanga v Namyalo Kevina and Another (MA No. 12 of 2017)

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

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

Ejulu v Itobu (HCMA 160 of 2022) [2023] UGHCCD 124 (26 April 2023)
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.