Kalemesa Samuel Wilson v Kaggwa Christopher Chris and Others (Miscellaneous Application No. 776 of 2023)
Observed later treatment
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Holding
The court held that an abated civil suit cannot be resurrected by way of an application for review. The word 'shall' in Order XIA rule 1(2) of the Civil Procedure (Amendment) Rules 2019, requiring a plaintiff to take out summons for directions within 28 days from the last reply, is mandatory unless exceptional circumstances under sub-rule 1(4) apply. The applicant failed to prove any exceptional circumstances. The proper remedy where a suit has abated is to file a fresh suit subject to the law of limitation. The application for review was dismissed.
Outcome
Application for review dismissed; main suit remains abated; applicant may file a fresh suit subject to limitation
Facts
The plaintiff filed HCCS No. 389 of 2022 on 11 May 2022 seeking recovery of land. All defendants filed their defences between 27 May and 7 June 2022. The plaintiff also filed an application for temporary injunction which was dismissed on 26 October 2022. The plaintiff failed to take out summons for directions within 28 days from the last reply as required by Order XIA rule 1(2) of the Civil Procedure (Amendment) Rules 2019. On 24 March 2023, counsel for the 3rd defendant wrote to court requesting abatement. On 27 March 2023, the court abated the suit for failure to take out summons for directions. The applicant then filed this application on 20 April 2023 seeking review and setting aside of the abatement order, arguing he was denied a fair hearing and that the requirement was discretionary, not mandatory. The applicant had belatedly attempted to file summons for directions on 19 January 2023, well beyond the 28-day deadline.
Issues
- Whether the court can review its decision to abate HCCS 389 of 2022 and set aside the same.
- Whether the applicant was denied a fair hearing in relation to the summons for directions before the abatement order was made.
- Whether the word 'shall' in Order XIA rule 1(2) of the Civil Procedure (Amendment) Rules 2019 is mandatory or discretionary.
- Whether exceptional circumstances existed to prevent abatement under Order XIA rule 1(4) of the Civil Procedure (Amendment) Rules 2019.
- Whether an abated suit can be resurrected by way of an application for review.
Orders
- Application dismissed.
- Each party to bear its own costs.
Rules and key headnotes
Legislation cited (16)
- Civil Procedure Act s.98
- Civil Procedure Act s.82
- Civil Procedure Rules Order 52 r.1
- Civil Procedure Rules Order 52 r.2
- Civil Procedure Rules Order 52 r.3
- Civil Procedure Rules Order 46
- Civil Procedure (Amendment) Rules 2019 Order XIA r.1(2)
- Civil Procedure (Amendment) Rules 2019 Order XIA r.1(4)
- Civil Procedure (Amendment) Rules 2019 Order XIA r.1(6)
- Civil Procedure (Amendment) Rules 2019 Order XIA r.1(7)
- Civil Procedure Rules Order VIII r.18(5)
- Civil Procedure Rules Order VI r.29
- Civil Procedure Rules Order VI r.30
- Civil Procedure Rules Order XV r.2
- Civil Procedure Rules Order XX
- Civil Procedure Rules Order XXXVI
Cases cited (7)
- Mukisa Biscuit Manufacturing Co. Ltd v West End Distributors (1969) 1 EA 696
- Re Nakivubo Chemists (U) Limited (1979) HCB 12
- Kanyabwera v Tumwebaze (Supreme Court Civil Appeal No. 6 of 2004)
- Waiswa v Army for Africa Limited and Others (HCCS No. 127 of 2020)
- Serugo v Swangz Avenue Limited (HCCA No. 39 of 2021)
- Seruwu v Swangz Avenue Limited (HCCA No. 39 of 2021)
- Sebalu v Njuba and The Electoral Commission (Supreme Court Election Petition Appeal No. 26 of 2007)
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.
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.