In The matter of An Application By Anyijukire For Appointment As Manager of Estate of A Person of Unsound Mind [2023] UGHC 119
Observed later treatment
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Holding
The High Court dismissed an ex parte application for appointment as manager of an estate of a person of unsound mind because the application was brought under the Administration of Estates of Persons of Unsound Mind Act Cap 155, which had been repealed by section 77(b) of the Mental Health Act 2019 before the application was filed. The court held that an application under a repealed law cannot stand and is incurable.
Outcome
Application dismissed for having been brought under repealed legislation
Facts
Anyijukire Wilber applied ex parte for appointment as manager of the estate of his father, Mutereba Isaiah, aged 75, who was receiving psychopharmacological and psychotherapy treatment at Care First Recovery Homes Uganda Ltd. The patient had been diagnosed with delusional disorder, was indebted to UGX 146,936,228, and incurred monthly maintenance costs of UGX 32,496,000. The application was filed by chamber summons on 27 September 2023 under the Administration of Estates of Persons of Unsound Mind Act Cap 155 and related Procedure Rules. The Mental Health Act 2019 had repealed Cap 155 by section 77(b) and came into force on 18 February 2021.
Issues
- Whether an application filed under a repealed statute can be maintained in court.
Orders
- Application dismissed.
Rules and key headnotes
Legislation cited (5)
- Administration of Estates of Persons of Unsound Mind Act Cap 155 s.2
- Administration of Estates of Persons of Unsound Mind (Procedure) Rules SI 155-1 rr.3,4,7,8,9
- Mental Health Act 2019 s.77(b)
- Interpretation Act Chapter 3 s.13
- Mental Health Act (Commencement) Instrument SI No.14 Of 2021 reg.2
Cases cited (1)
- Re Ayella Godfrey (Misc. Cause No. 226 of 2022)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.