Wakilii

Mugera v Uganda (HCT-00-ICD-CR-SC 2 of 2023)

High Court · [2023] UGHCICD 11 · 2023 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for bail arising from criminal trial pending in the High Court International Crimes Division
Decision
Applicant to remain on remand pending trial

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

Held that although the applicant demonstrated a fixed place of abode within the jurisdiction, the three sureties presented were not substantial. The sureties gravely contradicted the applicant on his place of residence, did not know him well enough, and had only business relationships rather than familial or close ties sufficient to compel his attendance. Given the gravity of the offences charged (terrorism and murder) and the absence of substantial sureties, the likelihood of absconding was high. Application for bail dismissed.

Outcome

Applicant to remain on remand pending trial

Facts

The applicant was charged with terrorism contrary to section 7(1)(A) and (2)(B) of the Anti-Terrorism Act 2002 and murder contrary to sections 188 and 189 of the Penal Code Act. He had been on remand at Luzira Upper Government Prison since September 2021 (eighteen months at the time of the application). He was committed for trial to the International Crimes Division of the High Court on 12 November 2021. Pre-trial conferencing had been ongoing since July 2022 and was not yet concluded. The applicant applied for bail arguing he had fixed places of abode at Kiyembe Zone, Kibuye II Parish, Makindye Division, Kampala and at Kyotera District where he operated a business, and that he had three sureties willing to guarantee his attendance. The state opposed, contending he lacked a fixed place of abode, the sureties were not substantial, the offences were grave involving personal violence, and he would abscond and interfere with witnesses.

Issues

  1. Whether the applicant has exceptional circumstances justifying his release on bail.
  2. Whether the applicant will abscond if granted bail, having regard to whether he has a fixed place of abode within the jurisdiction of the court.
  3. Whether the applicant has produced sound and substantial sureties within the jurisdiction to undertake that he shall comply with the conditions of bail.

Orders

  • Application for bail dismissed.

Rules and key headnotes

Bail — Fixed Place of Abode — Consistency of Evidence Required
An applicant for bail satisfies the requirement of a fixed place of abode where the applicant's affidavit, national identity card, charge sheet, and local council introductory letter consistently state the same residential address, notwithstanding contradictions introduced by sureties.
Bail — Substantiality of Sureties — Knowledge of the Accused
Sureties are not substantial where they gravely contradict the applicant on material facts such as his place of residence, demonstrate insufficient knowledge of the applicant, and share only a business relationship rather than familial or close personal ties sufficient to compel the accused's attendance at court.
Bail — Likelihood of Absconding — Gravity of Offence and Lack of Substantial Sureties
In determining the likelihood of an accused absconding, the court must consider the nature and gravity of the offences charged. Where the applicant is charged with grave offences involving personal violence and carrying a maximum sentence of death, and fails to produce substantial sureties, the likelihood of absconding is high and bail will be refused.

Legislation cited (12)

Cases cited (8)

  • Foundation for Human Rights Initiative v Attorney General (Constitutional Petition No. 20 of 2009)
  • Foundation for Human Rights Initiatives v Attorney General (Constitutional Appeal No. 3 of 2009)
  • Abindi Ronald and Another v Uganda (Miscellaneous Criminal Application No. 20 of 2016)
  • Tumwirukirire v Uganda (HCT-05-CV-MA-94 of 2019)
  • Dr. Ismail Kalule v Uganda (Miscellaneous Application No. 1 of 2018)
  • Tumusiime David v Uganda (HCT-MA-29-2019)
  • Kapisi Fred and Another v Uganda (HCT-05-CMA-108-2019)
  • Tigawalana Bakali Ikoba v Uganda (Criminal Appeal No. 23 of 2003)

Full judgment

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

Mugera v Uganda (HCT-00-ICD-CR-SC 2 of 2023) [2023] UGHCICD 11 (28 March 2023)
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.