Mukasa Micheal v Uganda [2026] UGHCCRD 62
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The applicant, charged with aggravated robbery and remanded from January 2022, sought mandatory release on bail under Article 23(6)(c) of the Constitution on the basis of prolonged pre-committal remand. The court found that the applicant had since been committed for trial and had already been granted bail by another judge on 21 August 2025. Accordingly, the application for mandatory bail could not be sustained as it had been overtaken by events, and it was dismissed.
Outcome
Application for mandatory bail dismissed as overtaken by events; applicant had already been committed and granted bail by another judge
Facts
The applicant was charged with aggravated robbery contrary to sections 266 and 267(2) of the Penal Code Act and was remanded on 20 January 2022. Contending that he had been on remand for two years and four months without committal for trial in respect of an offence triable only by the High Court, he applied for mandatory release on bail under Article 23(6)(c) of the Constitution. By the time of this ruling, the applicant had been committed for trial, and a bail application in his favour had already been granted by Hon. Justice Isaac Muwata on 21 August 2025.
Issues
- Whether the applicant is entitled to mandatory release on bail under Article 23(6)(c) of the Constitution having been on remand beyond the constitutional period without committal.
Orders
- The application for mandatory bail under Article 23(6)(c) of the Constitution is dismissed on the ground that the applicant has since been granted bail following the mandatory bail application by Hon. Justice Isaac Muwata on 21 August 2025.
Rules and key headnotes
Legislation cited (7)
- Constitution of the Republic of Uganda 1995 Article 23(6)(a)
- Constitution of the Republic of Uganda 1995 Article 23(6)(c)
- Trial on Indictments Act Cap 25 s.15
- Trial on Indictments Act Cap 25 s.16
- Penal Code Act Cap 128 s.266
- Penal Code Act Cap 128 s.267(2)
- Constitution (Bail Guidelines for Courts of Judicature) (Practice) Directions 2022
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.