Magolo John Faith v Wanyenya Shafiga (Miscellaneous Application No. 34 of 2026)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The court dismissed the application for substituted service as premature. Rule 6(4) of the Parliamentary Elections (Interim Provisions) (Election Petitions) Rules requires a petitioner to attempt personal service for three days before applying for substituted service. The applicant filed the petition on 31 March 2026 and the application on 1 April 2026, before the three-day period expired. Accounting for public holidays (Good Friday and Easter Monday), the proper filing date would have been 7 April 2026.
Outcome
Application for substituted service dismissed as premature
Facts
On 31 March 2026, the applicant filed Election Petition No. 5 of 2026 challenging the election of the respondent as Member of Parliament for Bungokho North Constituency following elections held on 15 January 2026. The applicant sought to serve the notice of presentation of the petition and accompanying documents on the respondent. On 1 April 2026, a court process server attempted service at the respondent's home in Bushiuyo village but found only a caretaker who stated the respondent had travelled to Kampala. The process server obtained the respondent's telephone number and attempted to call her several times without success, then served the petition via WhatsApp. The applicant also personally called the respondent but she did not answer. On 1 April 2026, the applicant filed this ex parte application for substituted service, supported by affidavits stating that all reasonable efforts to effect personal service had proved futile.
Issues
- Whether the applicant complied with the procedural requirements under Rule 6(4) of the Parliamentary Elections (Interim Provisions) (Election Petitions) Rules for filing an application for substituted service.
- Whether the application for substituted service was filed prematurely before the expiry of the three-day period for attempting personal service.
Orders
- Application dismissed.
- No order as to costs.
Rules and key headnotes
Legislation cited (11)
- Judicature Act Cap. 16 s.37
- Civil Procedure Act Cap. 282 s.98
- Parliamentary Elections (Interim Provisions) (Election Petition) Rules r.6(4)
- Parliamentary Elections (Interim Provisions) (Election Petition) Rules r.6(5)
- Civil Procedure Rules SI 71-1 Order 5 r.18
- Civil Procedure Rules SI 71-1 Order 5 r.32
- Parliamentary Elections (Interim Provisions) (Election Petitions) Rules r.6(1)
- Parliamentary Elections (Interim Provisions) (Election Petitions) Rules r.6(3)
- Interpretation Act Cap. 2 s.34(1)(b)
- Civil Procedure Rules SI 71-1 Order 51 r.3
- Public Holidays Act Cap. 174
Cases cited (1)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.