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, not constitutional enforcement proceedings. The application was an abuse of process as it sought to circumvent established administrative law remedies.
Outcome
Application dismissed for failure to disclose a cause of action under Article 50 of the Constitution
Facts
The applicant, an environmental advocacy organisation, brought an application under Article 50 of the Constitution alleging that the respondents violated environmental rights by allowing construction of Luzira Road in a wetland area without environmental approval. The applicant claimed that NEMA abdicated its regulatory duty, KCCA failed to control road construction, and the Commissioner for Land Registration irregularly issued titles for land in a wetland. On 12 July 2021, inspectors discovered soil dumping in the wetland by Moses Kamoga to create access to titled plots. The respondents opposed the application, contending that the applicant lacked standing and that no fundamental rights violation was demonstrated. The 4th, 6th and 7th respondents asserted they lawfully acquired titled land and denied their land was in a wetland.
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 (24)
- 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.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 Attorney General (Trinidad and Tobago) [1980] AC 265
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.