In the matter of the Estate of the Late Karegyeya Patrick (Miscellaneous Application 375 of 2025)

Observed later treatment

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.

Holding

Held that an administratrix who obtained letters of administration before the Succession (Amendment) Act, 2022 commenced may apply for extension under section 337(4) of the Succession Act by showing just cause. Where the administratrix was unable to perform her duties due to asylum status in the United States and has now obtained permanent resident status enabling her to travel to Uganda, and where beneficiaries consent to the extension, sufficient cause is established. Letters of administration extended for two years with one year granted to file inventory and exhibit account.

Outcome

Letters of administration extended for two years; administratrix granted one year to file inventory and account

Facts

The applicant was granted letters of administration for the estate of the late Karegyeya Patrick on 3rd May 2017. At the time of the grant, the applicant was resident in Maryland, United States of America, where she had fled with her children to seek asylum following her husband's death. Due to her asylum status, she was unable to travel to Uganda to fulfill her duties as administratrix and could not complete administration or file an inventory within the statutory period. The applicant's immigration status has since changed to permanent resident, enabling her to travel to Uganda to finalise estate matters. The beneficiaries of the estate consented to the application for extension.

Issues

1. Whether the applicant has shown sufficient cause to warrant extension of letters of administration granted before 31st May 2022.
2. Whether the applicant should be granted leave and extension of time to file an inventory.

Orders

• Application allowed.
• The Letters of Administration of the estate of the late Karegyeya Patrick granted to Leah Umuganwa Karegyeya vide Mbarara High Court Administration Cause HCT-05-CV-AC-0216-2016 are extended for a further period of two years from 17th October 2025.
• The Administratrix of the estate of the late Karegyeya Patrick shall file in court an inventory and exhibit an account within one year from 17th October 2025.

Rules and key headnotes

Legislation cited (14)

• Succession Act Cap 268 s.256
• Succession Act Cap 268 s.256(2)
• Succession Act Cap 268 s.256(3)
• Succession Act Cap 268 s.273
• Succession Act Cap 268 s.273(1)
• Succession Act Cap 268 s.337
• Succession Act Cap 268 s.337(2)
• Succession Act Cap 268 s.337(3)
• Succession Act Cap 268 s.337(4)
• Civil Procedure Act Cap 282 s.98
• Civil Procedure Rules S.I 71-1 Order 52 Rules 1, 2 & 3
• Judicature Act Cap 16 s.37
• Interpretation Act Cap 2 s.34(3)
• Judicature (Visual-Audio Link) Rules, 2016 Rules 4(B), 5(A), 5(F) and 6

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.

• Standard Chartered Bank (U) Ltd v Wilfred Bugingo (Civil Application No. 388 of 2025)

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