Wakilii

Karyeija v Others (Civil Application No. 120 of 2002)

Court of Appeal · [2003] UGCA 26 · 2003 Application Struck Out AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application by notice of motion for extension of time to institute an appeal and for an order permitting the legal representative of the deceased former plaintiff to institute the appeal.
Decision
Application struck out as incompetent with costs to the respondents

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The Court of Appeal held that no appeal can be instituted in the name of a dead person; it may only be instituted in the name of the deceased's legal representative, who must first apply to be substituted on record under Order 21 Rule 3 of the Civil Procedure Rules (or the equivalent rules of the court) before acquiring locus standi. The substitution application (Civil Application No. 75 of 2001) was not yet before the court, so there was nothing to which the present application could be tied. The application was incompetent and there was nothing to adjourn. The application was struck out with costs to the respondents.

Outcome

Application struck out as incompetent with costs to the respondents

Facts

The applicant sought an extension of time within which to institute an appeal against a High Court decision in Civil Suit No. 597/95, and an order permitting the legal representative of the deceased former plaintiff to institute the appeal. The former plaintiff had died before lodging an appeal. When the matter came up for hearing, counsel for the applicant sought an adjournment to secure a related application (Civil Application No. 75 of 2001) believed to deal with substitution of the deceased's legal representative. Counsel for the respondents objected, arguing that no application to substitute the legal representative was yet on record before the court, and that without an order putting the legal representative on record under Order 21 Rule 3, the legal representative had no locus standi. The court found that the substitution application was not before it, so there was nothing to adjourn for.

Issues

  1. Whether the court should grant an adjournment to enable the applicant to secure a related application (Civil Application No. 75 of 2001) which would substitute the legal representative for the deceased plaintiff.
  2. Whether an application for extension of time to appeal can be entertained where the legal representative of a deceased plaintiff has not first been put on record by court order.

Orders

  • Objection upheld.
  • Application struck out as incompetent.
  • Costs to the respondents.

Rules and key headnotes

Civil Procedure — Appeals — Death of Party — Appeal in name of deceased
No appeal may be instituted in the name of a dead person; an appeal can only be instituted in the name of the deceased's legal representative.
Civil Procedure — Substitution of Parties — Locus Standi of Legal Representative
A legal representative of a deceased party acquires locus standi to file or pursue an appeal or application only after first applying to be substituted on record for the deceased under Order 21 Rule 3 of the Civil Procedure Rules.
Civil Procedure — Adjournment — Incompetent Application
Where an application is incompetent because the legal representative has not been placed on record by court order, there is nothing to adjourn and the application will be struck out.

Legislation cited (5)

Cases cited (2)

  • Annah Kabunga v Leonia Karyeija and 2 Others (Civil Application No. 121 of 2002)
  • Uganda Corporation Creameries Ltd v Reamation Ltd (Civil Appeal No. 9 of 1998)

Full judgment

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

Karyeija v Others (Civil Application No. 120 of 2002) [2003] UGCA 26 (13 March 2003)
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.