Legal Rights for Sustainable Development (U) Ltd v National Environment Management Authority and Others (Miscellaneous Cause 202 of 2022)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The High Court dismissed an application brought under Article 50 of the Constitution seeking enforcement of environmental rights. The court held that the applicant failed to demonstrate how specific individual environmental rights had been violated. The allegations were complaints about performance of statutory functions by a public body and should have been pursued through judicial review rather than constitutional enforcement proceedings. The application was dismissed as it did not disclose a cause of action under Article 50.
Outcome
Application dismissed for failure to disclose a cause of action under Article 50 of the Constitution
Facts
The applicant, a company limited by guarantee established in 2019 to preserve the environment, brought an application in public interest alleging that construction of Luzira Road off Port Bell Road in Luzira was undertaken without environmental approval from NEMA. The applicant alleged that NEMA abdicated its regulatory duty, KCCA failed to control the construction, and the Commissioner for Land Registration irregularly issued titles for land in a wetland. On 12 July 2021, inspectors from the Wetlands Management Department discovered an excavator dumping soil in the wetland. Investigations revealed that Moses Kamoga was responsible for the dumping to create access to plots of land. The respondents opposed the application, contending that the applicant lacked locus standi and that no fundamental right violation was demonstrated. The 4th, 6th and 7th respondents asserted they lawfully acquired titled land and conducted due diligence.
Issues
- Whether the application is competently before the High Court.
- Whether the applicant is entitled to the remedies sought in the application.
Orders
- Application dismissed.
- No order as to costs since the matter revolves around public interest.
Rules and key headnotes
Legislation cited (25)
- Constitution of Uganda Article 20(2)
- Constitution of Uganda Article 39
- Constitution of Uganda Article 45
- Constitution of Uganda Article 50(1)
- Constitution of Uganda Article 50(2)
- Constitution of Uganda Article 237(2)(b)
- Judicature Act s.33
- Human Rights (Enforcement) Act s.3
- Human Rights (Enforcement) Act s.3(1)
- Human Rights (Enforcement) Act s.4
- Human Rights (Enforcement) Act s.6(3)
- Human Rights (Enforcement) Act s.10
- Judicature (Fundamental Rights & Other Freedoms) (Enforcement Procedure) Rules, 2019 Rule 7
- Judicature (Fundamental Rights & Other Freedoms) (Enforcement Procedure) Rules, 2019 Rule 8
- Civil Procedure Act s.98
- National Environmental Act s.3(1)
- National Environmental Act s.3(2)
- National Environmental Act s.3(3)
- National Environmental Act s.5(2)
- National Environmental Act s.55
- National Environmental Act s.110(1)
- National Environmental Act s.110(2)(c)
- National Environmental Act s.111(3)
- Land Act s.44
- Registration of Titles Act
Cases cited (2)
- Kimpi Isabirye v Attorney General and Another (Miscellaneous Cause No. 23 of 2017)
- Harrikisson v Att-Gen (Trinidad and Tobago) [1980] AC 265 at 268
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.