Male H. Mabirizi v Attorney General & Karuhanga & 5 Others v Attorney General & Uganda Law Society v Attorney General (Constitutional Appeal 2 of 2018; Constitutional Appeal 3 of 2
Observed later treatment
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Holding
The Supreme Court considered consolidated appeals challenging the Constitutional Court's upholding of the removal of presidential and Local Council V age limits by the Constitution (Amendment) Act No. 1 of 2018. The Court held that Article 102(b), prescribing the President's age qualification, is not part of the basic structure of the 1995 Constitution and was validly amended by Parliament under its Article 259 powers without a referendum. It found no derogation of the appellants' right to a fair hearing before the Constitutional Court and overruled the preliminary objections. The grounds challenging the basic-structure analysis, the enactment process, and the conduct of the hearing failed.
Outcome
Appeal dismissed (inferred from the failure of the resolved issues); the removal of presidential and Local Council V age limits by the Constitution (Amendment) Act No. 1 of 2018 upheld as valid. Final orders not visible in the provided text.
Facts
In September 2017, Hon. Raphael Magyezi, MP for Igara West, moved a private member's bill to amend the 1995 Constitution. After amendments at the committee-of-the-whole-House stage (including extending the tenure of Parliament and Local Government Councils from five to seven years and reinstating presidential term limits), Parliament passed the bill and the President assented to it on 27 December 2017, making it the Constitution (Amendment) Act No. 1 of 2018. The Act, among other things, removed the age limits (Articles 102(b) and 183) for the office of President and Local Council V Chairperson. Aggrieved citizens, including the appellants, petitioned the Constitutional Court at Mbale challenging the enactment process and provisions. By a 4-1 majority, the Constitutional Court struck down the provisions extending tenure and reinstating term limits, but upheld the removal of the age limits as validly passed. The appellants appealed to the Supreme Court against the upholding of the age-limit removal.
Issues
- Whether the learned Justices of the Constitutional Court misdirected themselves on the application of the basic structure doctrine.
- Whether the majority erred in holding that the entire process of conceptualizing, consulting, debating and enacting the Constitution (Amendment) Act No. 1 of 2018 did not contravene the 1995 Constitution and the Rules of Procedure of Parliament.
- Whether the Justices erred in holding that the violence/scuffle inside and outside Parliament during the enactment of the Act did not contravene the Constitution.
- Whether the Justices erred when they applied the substantiality test in determining the petition.
- Whether the majority misdirected themselves in holding that the removal of the age limit for the President and Local Council V offices was not inconsistent with the 1995 Constitution.
- Whether the Constitutional Court erred in holding that the President elected in 2016 is not liable to vacate office on attaining the age of 75 years.
- Whether the Justices derogated the appellants' right to a fair hearing, injudiciously exercised their discretion and committed the alleged procedural irregularities, and if so, what is the effect on the decision of the Court.
- What remedies are available to the parties.
Rules and key headnotes
Legislation cited (40)
- Constitution of Uganda 1995 art.1
- Constitution of Uganda 1995 art.2
- Constitution of Uganda 1995 art.3
- Constitution of Uganda 1995 art.8A
- Constitution of Uganda 1995 art.28
- Constitution of Uganda 1995 art.44
- Constitution of Uganda 1995 art.79
- Constitution of Uganda 1995 art.93
- Constitution of Uganda 1995 art.94
- Constitution of Uganda 1995 art.102(b)
- Constitution of Uganda 1995 art.105(1)
- Constitution of Uganda 1995 art.107
- Constitution of Uganda 1995 art.126
- Constitution of Uganda 1995 art.137(3)
- Constitution of Uganda 1995 art.137(4)
- Constitution of Uganda 1995 art.183(2)(b)
- Constitution of Uganda 1995 art.255
- Constitution of Uganda 1995 art.259
- Constitution of Uganda 1995 art.260
- Constitution of Uganda 1995 art.262
- Constitution of Uganda 1995 art.263
- Constitution (Amendment) Act No. 1 of 2018 ss.1, 3, 4, 7
- Constitution (Amendment) Act No. 1 of 2018 ss.2, 5, 6, 8, 9, 10
- Supreme Court Rules r.2(2)
- Supreme Court Rules r.78
- Supreme Court Rules r.82
- Supreme Court Rules r.88
- Supreme Court Rules r.98
- Evidence Act (Cap. 8) s.73
- Evidence Act (Cap. 8) s.75
- Evidence Act (Cap. 8) s.76
- Evidence Act (Cap. 8) s.137
- Budget Act s.10
- Public Finance Management Act 2015 s.76
- Civil Procedure Rules O.21
- Rules of Procedure of Parliament r.121
- Rules of Procedure of Parliament r.123
- Rules of Procedure of Parliament r.124
- Rules of Procedure of Parliament r.129
- Rules of Procedure of Parliament r.201(2)
Cases cited (26)
- Ssemwogerere v Attorney General (Constitutional Appeal No. 1 of 2002)
- Attorney General v Tinyefuza (Constitutional Appeal No. 1 of 1997)
- Attorney General v Abuki (Constitutional Appeal No. 1 of 1998)
- Attorney General v Uganda Law Society (Constitutional Appeal No. 1 of 2006)
- Okello v Attorney General (Constitutional Petition No. 4 of 2005)
- Kobusingye v Nyakana (Civil Appeal No. 5 of 2008)
- Hwang Sung Ltd v M & D Timber Merchants and Transporters Ltd (Civil Appeal No. 2 of 2018)
- Matembe v Attorney General (Constitutional Petition No. 2 of 2005)
- Cardinal Nsubuga vs Makula International Ltd (1982)
- Patel v Wambuga (Civil Appeal No. 6 of 2017)
- Bitamisi v Rwabuganda (Civil Appeal No. 16 of 2014)
- Hamid v Roko Construction (Civil Appeal No. 1 of 2013)
- Serugo v Kampala City Council & Anor (Civil Appeal No. 2 of 1998)
- Baku Raphael & Anor v Attorney General (Civil Appeal No. 1 of 2003)
- Nsekikubo & Others v Attorney General (Constitutional Appeal No. 1 of 2015)
- Mbogo & Others v Shah [1968] EA 93
- British American Tobacco (U) Ltd v Mwijukubi & 4 Others (Civil Appeal No. 1 of 2012)
- Tororo Cement Co. Ltd v Frokina International Ltd (Civil Appeal No. 2 of 2001)
- American Express International Banking Ltd v Atul [1990-94] EA 10
- Kesavananda Bharati v State of Kerala AIR 1973 SC 1461
- Minerva Mills Ltd v Union of India AIR 1980 SC 1789
- Anwar Hossain Chowdhury v Bangladesh 41 DLR (1989) AD 165
- Executive Council of the Western Cape Legislature v President of the Republic of South Africa [1995] ZACC 8
- Njoya & Others v Attorney General & Others [2004] LLR 4788 (HCK)
- Attorney General v Rev. Christopher Mtikila (Civil Appeal No. 45 of 2009)
- Mbabazi v Museveni (Presidential Election Petition No. 1 of 2016)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.