Kagoro Deo V Uganda (Criminal Appeal No. 82 of 2011)
Observed later treatment
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Holding
The Court of Appeal held that Article 23(8) of the Constitution, requiring deduction of pre-trial remand time, does not apply to life imprisonment because life imprisonment, as defined by the Supreme Court in Tigo Stephen, means imprisonment for the natural life of the convict—an indeterminate term from which a fixed remand period cannot be deducted. The Prisons Act's deeming of life imprisonment as 20 years applies only to calculating remission. However, the court found the life sentence manifestly harsh and excessive when measured against comparable precedents, set it aside, substituted 22 years, deducted 2 years on remand, and imposed 18 years' imprisonment.
Outcome
Appeal partly allowed; life imprisonment set aside and substituted with 18 years' imprisonment running from 17 March 2011.
Facts
The appellant, aged 63 at the time of the offence, performed a sexual act with K.A., a girl aged 2½ years who was his granddaughter (the daughter of his son). He was indicted for aggravated defilement contrary to section 129(1),(4)(a) of the Penal Code Act, tried and convicted in the High Court at Fort Portal, and sentenced to life imprisonment. The appellant had spent about 2 years on pre-trial remand. He appealed against sentence only, contending that the life sentence was illegal because the trial judge had not deducted the remand period as required by Article 23(8) of the Constitution, and in the alternative that the sentence was manifestly harsh and excessive.
Issues
- Whether the period a convict spends in lawful custody prior to conviction must be taken into account under Article 23(8) of the Constitution when imposing a sentence of life imprisonment.
- Whether the sentence of life imprisonment imposed on the appellant for aggravated defilement was manifestly harsh and excessive.
Orders
- First limb of the appeal (illegality for non-deduction of remand) dismissed.
- Appeal allowed on the ground that the sentence of life imprisonment was harsh and excessive.
- Sentence of life imprisonment set aside.
- Sentence of 22 years substituted, less 2 years spent on remand, resulting in 18 years' imprisonment running from the date of conviction on 17 March 2011.
Rules and key headnotes
Legislation cited (11)
- Penal Code Act Cap 120 s.129(1),(4)(a)
- Penal Code Act Cap 120 s.1
- Constitution of the Republic of Uganda 1995 art.23(8)
- Constitution of the Republic of Uganda 1995 art.28(12)
- Constitution of the Republic of Uganda 1995 art.21(1)
- Constitution (Sentencing Guidelines for Courts of Judicature) (Practice) Directions, 2013 rule 15
- Prisons Act Cap 304 s.47(6)
- Prisons Act Cap 304 s.46(6)
- Prisons Act 2006 s.86(3)
- Prisons Act 2006 s.125
- Judicature Act s.11
Cases cited (18)
- Rwabugande Moses v Uganda (Criminal Appeal No. 25 of 2014)
- Tigo Stephen v Uganda (Criminal Appeal No. 8 of 2009)
- Kia Erin v Uganda (Criminal Appeal No. 172 of 2013)
- Okello William v Uganda (Criminal Appeal No. 146 of 2014)
- Abelle Asuman v Uganda (Criminal Appeal No. 66 of 2016)
- Attorney General v Susan Kigula and 417 Others (Constitutional Appeal No. 3 of 2006)
- Ssekawoya Blasio v Uganda (Criminal Appeal No. 24 of 2014)
- R v Foy [1962] 2 All ER 245
- Wamutabanewe Jamiru v Uganda (Criminal Appeal No. 74 of 2007)
- Magezi Gad v Uganda (Criminal Appeal No. 17 of 2014)
- Kyalimpa Edward v Uganda (Criminal Appeal No. 10 of 1995)
- Ogalo s/o Owoura v R (1954) 21 EACA 270
- R v Mohamedali Jamal (1948) EACA 126
- Katende Ahamad v Uganda (Criminal Appeal No. 6 of 2004)
- Babua Roland v Uganda (Criminal Appeal No. 303 of 2010)
- Kizito Senkula v Uganda (Criminal Appeal No. 24 of 2001)
- Ninsiima Gilbert v Uganda (Criminal Appeal No. 0180 of 2010)
- Lukwago Henry v Uganda (Criminal Appeal No. 0036 of 2010)
Cases citing this judgment (5)
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.
Full judgment
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