Wakilii

James Turyatemba v Dickens Ahimbisibwe (Civil Appeal No.39 of 2024)

High Court · [2025] UGHC 1506 · 2025 Appeal Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Civil appeal from Chief Magistrate's Court judgment in summary suit for debt recovery
Decision
Appeal dismissed with costs; judgment of the Chief Magistrate's Court affirmed

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The High Court dismissed the appeal, holding that where a defendant in a summary suit admits the full amount claimed and raises no triable issue of law or fact, the trial court properly enters judgment under Order 36 Rules 3 and 5 of the Civil Procedure Rules. A formal demand notice is not a prerequisite for instituting a summary suit, and willingness to pay without more does not constitute a defence.

Outcome

Appeal dismissed with costs; judgment of the Chief Magistrate's Court affirmed

Facts

The respondent instituted a summary suit under Order 36 of the Civil Procedure Rules seeking recovery of UGX 2,600,000, being the balance of a loan of UGX 4,600,000 advanced to the appellant for a thanksgiving ceremony. The parties agreed repayment by 23 April 2021. The appellant paid UGX 2,000,000 but defaulted on the balance. The appellant filed a motion seeking leave to appear and defend, admitting the debt and expressing willingness to pay. At the hearing, the appellant again admitted owing the balance and prayed for dismissal of the suit on account of his readiness to pay. The trial magistrate found that the appellant had admitted liability for the full amount claimed and dismissed the application for leave to appear and defend, entering judgment for the plaintiff under Order 36 Rules 3 and 5 with costs. The appellant appealed, arguing that the respondent failed to issue a demand notice and notice of default before filing suit.

Issues

  1. Whether the learned trial magistrate erred in law and fact when she overlooked the evidence of the failure of the respondent to issue a demand notice and a notice of default before arriving at the conclusion that the applicant had defaulted.
  2. Whether the trial magistrate erred in denying the appellant leave to appear and defend and entering judgment for the plaintiff.

Orders

  • Appeal dismissed.
  • Costs awarded to the respondent.

Rules and key headnotes

Civil Procedure — Summary Suits — Leave to Appear and Defend — Admission of Liability
Where a defendant in a summary suit under Order 36 of the Civil Procedure Rules admits the full amount claimed in both affidavit and oral submissions and raises no triable issue of law or fact, the court properly refuses leave to appear and defend and enters judgment for the plaintiff under Order 36 Rules 3 and 5.
Civil Procedure — Summary Suits — Requirements for Leave to Defend
For leave to appear and defend a summary suit to be granted, an applicant must show by affidavit or otherwise that there is a bona fide triable issue of fact or law. Willingness to pay the admitted debt, without more, does not constitute a substantial or triable issue and is not a ground for defending a summary suit.
Civil Procedure — Summary Suits — Demand Notice — Not a Prerequisite
The law on summary procedure under Order 36 of the Civil Procedure Rules does not require the service of a formal demand notice before instituting suit. The absence of a demand notice does not render a summary suit incompetent.

Legislation cited (5)

Cases cited (4)

  • J. Muluta v S. Katama (Supreme Court Civil Appeal No. 11 of 1999)
  • Fr. Narensio Begumisa and 3 Others v Eric Kibebaga (Supreme Court Civil Appeal No. 17 of 2002)
  • Maluku Interglobal Trade Agency Ltd v Bank of Uganda [1985] HCB 65
  • Kotecha v Adam Mohammed [2002] 1 EA 112

Full judgment

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

James Turyatemba v Dickens Ahimbisibwe (Civil Appeal No.39 of 2024) [2025] UGHC 1506 (26 June 2025)
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.