Wakilii

Kabuleta v Attorney General (Miscellaneous Cause 8 of 2023)

High Court · [2023] UGHCCD 414 · 2023 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for enforcement of human rights of 32 detainees charged at General Court Martial and remanded at Kitalya government prison
Decision
Application for enforcement of human rights dismissed; detainees remain in custody pending trial at General Court Martial

Observed later treatment

No later-treatment classification is recorded for this judgment.

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.

AI-generated summary. This summary was generated by AI from the full text of the judgment. It may contain errors or omissions—always read the source judgment before relying on it.

Holding

Held that civilians charged with unlawful possession of ammunition ordinarily the monopoly of the Defence Forces become subject to military law under UPDF Act s.119(1)(h) and may be tried by the General Court Martial. Where detainees are under trial and witnesses have testified, the provisions of UPDF Act s.190(3) requiring release after 90 days do not apply. Application for unconditional release and compensation dismissed.

Outcome

Application for enforcement of human rights dismissed; detainees remain in custody pending trial at General Court Martial

Facts

Thirty-two persons were arrested between 10 May 2021 and 30 May 2021 and charged before the General Court Martial with unlawful possession of ammunition ordinarily the monopoly of the Defence Forces contrary to UPDF Act s.119(1)(h). They were remanded to Kitalya government prison and denied bail. The applicant, Kabuleta Joseph Kiiza, filed an application seeking their immediate release, arguing that their continued detention beyond 90 days violated UPDF Act s.190(3) and their constitutional rights to personal liberty. The respondent opposed, stating that the accused persons were properly charged, their trial had commenced with one witness having testified, and they had applied for bail which was denied in the court's discretion. A further bail application was pending.

Issues

  1. Whether the criminal proceedings and trial vide Criminal Case UPDF/GCM/072/2021 are lawful
  2. Whether the continued detention of the 32 detainees is lawful and legal
  3. What remedies are available to the applicant

Orders

  • Application dismissed.
  • No order as to costs.

Rules and key headnotes

Military Law — Jurisdiction — Civilians Subject to Military Law
Civilians found in unlawful possession of arms, ammunition or equipment ordinarily being the monopoly of the Defence Forces become subject to military law under UPDF Act s.119(1)(h) and may be tried by the General Court Martial.
Military Law — Detention Limits — Application of UPDF Act s.190(3)
Where detainees charged under military law are under trial and witnesses have testified against them, the provisions of UPDF Act s.190(3) requiring release after 90 days do not apply.
Personal Liberty — Unreasonable Detention — Burden of Proof
Under Human Rights (Enforcement) Act s.15, the onus is on the applicant seeking unconditional release to prove that the detention is unreasonable, irregular, unlawful, or amounts to a miscarriage of justice.

Legislation cited (31)

Cases cited (3)

  • Namugerwa Hadijah v Attorney General (Supreme Court Criminal Appeal No. 4 of 2012)
  • Attorney General v Uganda Law Society (Constitutional Appeal No. 1 of 2006)
  • Uganda Law Society vs. Attorney General (supra)

Full judgment

↓ Download PDF

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

Kabuleta v Attorney General (Miscellaneous Cause 8 of 2023) [2023] UGHCCD 414 (11 April 2023)
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.