Wakilii

Kwoba v Barasa Mariko and 3 Others (CIVIL APPEAL NO 0013 OF 2023)

High Court · [2024] UGHC 1240 · 2024 Appeal Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Civil appeal from Chief Magistrate's Court judgment dismissing suit for customary land ownership declaration
Decision
Appeal dismissed summarily as incompetent for being filed out of time without leave

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

An appeal filed more than thirty days after the record of proceedings was certified to the appellant, without leave for extension of time, is incompetent and must be dismissed. Time begins to run only when the record becomes available to the intending appellant. Where leave is required but not obtained, the appeal cannot proceed.

Outcome

Appeal dismissed summarily as incompetent for being filed out of time without leave

Facts

The appellant sued respondents in the Chief Magistrate's Court for a declaration of customary ownership over 35 acres of land in Buhera Village, alleging he inherited the land from his late father who died in 2004. The respondents defended that the first and second respondents inherited the land from their father who had purchased it from the appellant's father in 1984, more than 30 years prior, and that the third and fourth respondents were bona fide purchasers from the first and second respondents. After trial including a locus visit, the Chief Magistrate dismissed the appellant's suit with costs on 22 September 2022. The appellant requested certified proceedings on 26 September 2022, received them on 24 March 2023, and filed the appeal on 6 June 2023—73 days after certification.

Issues

  1. Whether the appeal was filed within the statutory time limit prescribed under Section 79(1)(a) of the Civil Procedure Act.
  2. Whether the appeal is competent having been filed 73 days after the record of proceedings was certified without seeking leave for extension of time.

Orders

  • Preliminary objection upheld.
  • Appeal dismissed summarily.
  • Costs awarded to the Respondents.

Rules and key headnotes

Civil Procedure — Appeals — Time Limits — Computation of Time — When Time Begins to Run
Time for filing an appeal to the High Court begins to run only from the date the record of proceedings is availed to the intending appellant, not from the date of the decree or order.
Civil Procedure — Appeals — Time Limits — Extension of Time — Requirement for Leave
An appeal filed after the thirty-day period prescribed by Section 79(1)(a) of the Civil Procedure Act requires leave for extension of time. Where such leave is not obtained, the appeal is incompetent and must be dismissed.
Civil Procedure — Appeals — Incompetent Appeals — Effect of Filing Without Leave
Where leave is required to file an appeal and such leave is not obtained, the appeal filed is incompetent and cannot even be withdrawn as an appeal.

Legislation cited (2)

  • Civil Procedure Act Cap.71 s.79(1)(a)
  • Civil Procedure Act Cap.71 s.79(2)

Cases cited (3)

  • Sekabira Herbert v Suuna Mulema and Another (HCMA No. 186 of 2022)
  • Makhangu v Kibwana [1995-1998] 1 EA 175
  • Dr. Sheikh Ahmed Muhammed Kisuule v Greenland Bank (In Liquidation) (Supreme Court Civil Appeal No. 11 of 2010)

Full judgment

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

Kwoba v Barasa Mariko and 3 Others (CIVIL APPEAL NO 0013 OF 2023) [2024] UGHC 1240 (6 March 2024)
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.