Katureebe v Uganda (Criminal Appeal No. 174 of 2012)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The Court of Appeal dismissed the appellant's appeal against a 30-year sentence for murder. The court held that an appellate court should not interfere with a trial court's sentencing discretion unless it acted on a wrong principle, overlooked a material factor, or the sentence was illegal or manifestly excessive. Applying the Sentencing Guidelines and the aggravating factors found by the trial judge, the court found the sentence was not harsh or excessive. It further held, following Abelle Asuman, that the constitutional command under Article 23(8) to take into account the remand period need not be arithmetical, and that the trial judge had duly considered the remand period.
Outcome
Appeal dismissed; conviction and sentence of 30 years' imprisonment upheld
Facts
The deceased, Kyomuhangi Edvina, was the wife of the appellant. On 19th March 2005, she went to Kyemamba market where she prepared and sold food. At 9:00pm she went via Mutabazi's home to pay him for goods taken during the day, then returned home. At 5:00am the appellant went to Mutabazi's home and told him to come and see the deceased's body. On arrival Mutabazi found the deceased lying dead on the floor. When asked what had happened, the appellant said he woke up and found her dead. The appellant then disappeared, fleeing to the bush, from where he was arrested. He was tried and convicted of murder and sentenced to 30 years' imprisonment. He appealed against sentence only, contending it was harsh and excessive and that the trial court had failed to consider his remorse.
Issues
- Whether the sentence of 30 years' imprisonment imposed on the appellant for murder was harsh and manifestly excessive.
- Whether the trial court took into account the period the appellant spent on remand as required by Article 23(8) of the Constitution.
Orders
- The conviction and sentence of the trial court are upheld.
- The appeal is dismissed.
Rules and key headnotes
Legislation cited (6)
- Penal Code Act s.188
- Penal Code Act s.189
- Trial on Indictments Act s.132(1)
- Constitution of Uganda Article 23(8)
- Constitution (Sentencing Guidelines for Courts of Judicature) Practice Directions, Legal Notice No. 8 of 2013
- Court of Appeal Rules r.30
Cases cited (8)
- Pandya v. R [1957] EA 336
- Okeno v R [1972] EA 32
- Charles Bitwire v Uganda (Criminal Appeal No. 23 of 1985)
- Kifamunte Henry v Uganda (Criminal Appeal No. 10 of 1997)
- Kyalimpa Edward v Uganda (Criminal Appeal No. 10 of 1995)
- Kyewalabye Bernard v Uganda (Criminal Appeal No. 143 of 2001)
- Rwabugande Moses v Uganda (Criminal Appeal No. 25 of 2014)
- Abelle Asuman v Uganda (Criminal Appeal No. 66 of 2016)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.