Wakilii

Kasoro & Anor v Bonabana (Miscellaneous Application No. 002 of 2016)

High Court · [2016] UGHCLD 12 · 2016 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for review of appellate judgment arising from Civil Appeal No. 37 of 2016
Decision
Application for review dismissed with costs

Observed later treatment

Cited — treatment unverified cited in 2 (treatment unverified) Sequitur — Uganda’s citator · Derived from citing cases in the Wakilii corpus — not an assertion that this case is good law.

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.

No adverse treatment recorded Cited 2 times with no adverse treatment recorded; not yet tested on the merits. Derived from citing cases in the Wakilii corpus — a deterministic signal, not legal advice.

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

An appellate court's failure to re-evaluate evidence does not constitute an error apparent on the face of the record warranting review, but rather a ground for further appeal. Review jurisdiction cannot be used to circumvent time limits for filing appeals. The application for review brought five years after judgment, when the proper remedy was an appeal within thirty days, was dismissed as an abuse of process.

Outcome

Application for review dismissed with costs

Facts

The applicants sought review of an appellate judgment delivered in July 2015 dismissing their appeal in a land dispute. The underlying suit concerned ownership of land at Maguru in Fort Portal Municipality. The trial court had dismissed the plaintiff's claim that she was the lawful owner, finding the land belonged to the late Kasoro Charles. The appellate court dismissed the appeal. Five years later, in 2016, after the respondent served a bill of costs and initiated execution, the applicants applied for review, arguing that the appellate court failed to exercise its duty to re-evaluate and re-appraise the evidence as required by law.

Issues

  1. Whether the first appellate court failed to exercise its jurisdiction by not re-evaluating, re-appraising and scrutinising the evidence as required under Section 80(1)(a) and (b) of the Civil Procedure Act.
  2. Whether the alleged failure to exercise appellate jurisdiction constitutes an error apparent on the face of the record warranting review under Section 82 of the Civil Procedure Act and Order 46 of the Civil Procedure Rules.

Orders

  • Application for review dismissed.
  • Costs awarded to the respondent.

Rules and key headnotes

Civil Procedure — Review of Judgment — Error Apparent on Face of Record — Distinction from Grounds of Appeal
An appellate court's failure to re-evaluate, re-appraise and scrutinise evidence as required by Section 80 of the Civil Procedure Act does not constitute an error apparent on the face of the record warranting review, but rather a ground for further appeal to a higher court.
Civil Procedure — Review of Judgment — Time Limits — Abuse of Process
Although there is no statutory time limit for filing an application for review, review jurisdiction cannot be used as a substitute for appeal where the proper remedy was to file an appeal within the prescribed time limit or to apply for extension of time to appeal.
Civil Procedure — Review of Judgment — Grounds for Review — Section 82 Civil Procedure Act
Review under Section 82 of the Civil Procedure Act and Order 46 of the Civil Procedure Rules is available only on specific grounds including discovery of new and important evidence not previously available, mistake or error apparent on the face of the record, or other sufficient reason, and cannot be invoked merely because a party is dissatisfied with the judgment.

Legislation cited (6)

Cases cited (3)

  • Banco Araba Esponol v Bank of Uganda (Supreme Court Civil Appeal No. 8 of 1998)
  • Edson Kanyabweru v Pastori Tumwebaze (Supreme Court Civil Appeal No. 6 of 2004)
  • A.G & ULC Vs James Marting Kamoga & James Kamuli

Cases citing this judgment (2)

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

Kasoro & Anor v Bonabana (Miscellaneous Application No. 002 of 2016) [2016] UGHCLD 12 (22 June 2016)
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.