Henry Kayondo v Uganda (Criminal Appeal No. 35 92)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The Supreme Court dismissed the appeal. Whether the two letters were "official documents" under the Official Secrets Act, and whether the NRM Secretariat is a government department, are questions of evidence to be determined at trial, not on a preliminary objection. The charges gave reasonable information as to their nature and disclosed offences. The alternative charge of retaining stolen property need not be a minor and cognate offence and was properly joined under section 84 of the Magistrates' Courts Act, being founded on the same facts. Section 124 Evidence Act privilege was displaced by the proviso for communications made in furtherance of an illegal purpose. The Court doubted that the preliminary objections were even authorised under the Magistrates' Courts Act.
Outcome
Appeal dismissed; the charges stand and the matter proceeds to trial before the Magistrate's Court
Facts
The appellant was charged before a Magistrate's Court on two counts of unlawfully and prejudicially retaining an official document contrary to section 3(4)(a) of the Official Secrets Act. Count one concerned a letter written to the Administrative Secretary, National Resistance Movement Secretariat, and count two a letter to the Director of Research and Political Affairs, Office of the President. In the alternative, the appellant was charged with retaining stolen property (the same two documents) contrary to section 296(1) of the Penal Code. At the hearing the defence raised three preliminary objections: that the letters were not official documents as defined in section 15(1) of the Official Secrets Act; that the NRM Secretariat is not a Government department; and that the alternative charge would embarrass the accused. The Chief Magistrate overruled all three objections. The appellant's petition to the High Court for revision was dismissed, and he appealed to the Supreme Court.
Issues
- Whether the letters that were the subject of the charges were "official documents" within the meaning of section 15 of the Official Secrets Act, such that the question could be determined on a preliminary objection rather than by evidence at trial.
- Whether the National Resistance Movement Secretariat is a department of Government so that documents to or from it are government documents.
- Whether the alternative charge of retaining stolen property was properly joined to the substantive counts.
- Whether section 124 of the Evidence Act protected the relevant communications from disclosure.
- Whether the preliminary objections to the charges were competent and authorised under the Magistrates' Courts Act.
Orders
- The appeal is accordingly dismissed.
Rules and key headnotes
Legislation cited (17)
- Official Secrets Act (Cap. 311) s.3(4)(a)
- Official Secrets Act (Cap. 311) s.15(1)
- Official Secrets Act (Cap. 311) s.1
- Penal Code Act s.296(1)
- Evidence Act s.124
- Magistrates' Courts Act 1970 s.83
- Magistrates' Courts Act 1970 s.84
- Magistrates' Courts Act 1970 s.143
- Magistrates' Courts Act 1970 s.41
- Magistrates' Courts Act 1970 s.34
- Magistrates' Courts Act 1970 s.35
- Magistrates' Courts Act 1970 s.36
- Magistrates' Courts Act 1970 s.130
- Trial on Indictments Decree 1971 s.48
- Trial on Indictments Decree 1971 s.50
- Trial on Indictments Decree 1971 s.51
- Trial on Indictments Decree 1971 s.56
Cases cited (3)
- Robinson v.Barton Eccles Local Board
- Ex.p. Ferguson
- Samuels v Republic [1965] EA 1
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.