Godwin Asiimwe and Another v Uganda (Criminal Appeal 4 of 2024)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Appeal dismissed. Held that amendment of the charge sheet figure from UGX 23,556,000 to UGX 24,686,000 did not constitute new facts requiring fresh consent under Anti-Corruption Act s.49. The trial court properly convicted the 1st Appellant of abuse of office, both Appellants of causing financial loss, and the 1st Appellant of false accounting. Safari day allowance claims for activities within 40 kilometres and multiple claims on the same day violated Public Service Standing Orders and constituted arbitrary acts prejudicial to the employer. Sentences were not excessive. Disqualification from public office for 10 years was mandatory under Anti-Corruption Act s.46.
Outcome
Appellants' convictions and sentences upheld; 1st Appellant to pay fine of UGX 11,520,000 in default of 7 years imprisonment and refund UGX 7,200,000; 2nd Appellant to pay fine of UGX 4,000,000 in default of 18 months imprisonment and refund UGX 2,640,000; both disqualified from public office for 10 years
Facts
The 1st Appellant was Town Treasurer and the 2nd Appellant was Accounts Assistant at Kabale Municipal Council, Northern Division between 1 July 2015 and 30 April 2016. The 1st Appellant facilitated payments of Safari Day Allowance totalling UGX 24,686,000 for activities that did not meet the conditions for such allowance under the Public Service Standing Orders. The activities were conducted within Kabale Municipal Council Northern Division, which measured only 9.65 square kilometres, well below the 40-kilometre distance requirement for safari day allowance. Multiple allowances were claimed for separate activities on the same day, resulting in claims exceeding the actual number of days in the period. Both Appellants irregularly requisitioned, authorised, and paid out these funds. The 1st Appellant furnished false accountabilities covering the payments. They were convicted by the Chief Magistrate's Court on charges of abuse of office, causing financial loss, and false accounting.
Issues
- Whether the trial court erred in proceeding with the hearing on an amended charge sheet that had not been consented to by the Inspector General of Government as required under the Anti-Corruption Act s.49.
- Whether the trial magistrate properly evaluated the evidence in convicting the 1st Appellant on the charge of Abuse of Office contrary to Anti-Corruption Act s.11(1).
- Whether the trial magistrate properly evaluated the evidence in convicting both Appellants on the charge of Causing Financial Loss contrary to Anti-Corruption Act s.20(1).
- Whether the trial magistrate properly evaluated the evidence in convicting the 1st Appellant on the charge of False Accounting by a Public Officer contrary to Anti-Corruption Act s.22.
- Whether the sentences imposed by the trial magistrate were harsh, excessive, and manifestly unjust.
- Whether the trial magistrate erred in ordering the Appellants to refund specific sums to Kabale Municipal Council without cogent evidence.
- Whether the trial magistrate erred in disqualifying the Appellants from holding public office for 10 years.
Orders
- Appeal wholly dismissed on grounds of lack of merit.
- Conviction and sentence of the lower court upheld.
- Right of appeal explained.
Rules and key headnotes
Legislation cited (8)
- Anti-Corruption Act s.11(1)
- Anti-Corruption Act s.20(1)
- Anti-Corruption Act s.22
- Anti-Corruption Act s.46
- Anti-Corruption Act s.49
- Public Service Standing Orders 2010 Paragraph E-b Items 11-13
- Constitution (Sentencing Guidelines for Courts of Judicature) (Practice) Directions 2013 paragraph 6
- Constitution (Sentencing Guidelines for Courts of Judicature) (Practice) Directions 2013 paragraph 41
Cases cited (11)
- Kifamunte Henry v Uganda (Supreme Court Criminal Appeal No. 10 of 1997)
- Bogere Moses and Another v Uganda (Supreme Court Criminal Appeal No. 1 of 1997)
- Kinhyua Vs Republic (1972) 1 EA 54 (HCK)
- Dr. John Mudusu v Uganda (Criminal Appeal No. 67 of 1999)
- Andrua and Another v Uganda (Criminal Appeal No. 17 of 2016)
- Uganda v Nalubega Sansa Mwajuma and Another (Criminal Appeal No. 5 of 2018)
- Lwamafa Jimmy and 2 Others v Uganda (Criminal Appeal No. 257 of 2015)
- Lwamafa Jimmy and 2 Others v Uganda (Criminal Appeal No. 357 of 2016)
- Uganda v Kakande Mike Alias Ojara (Criminal Session Case No. 273 of 2015)
- Uganda v Nakiwuge Rachel Muleke (High Court Anti-Corruption Session Case No. 15 of 2014)
- Kyalimpa Edward v Uganda (Supreme Court Criminal Appeal No. 10 of 1995)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.