Wakilii

Murenegzi Moses and Others v Kisoro District Local Government (Civil Suit 49 of 2017)

High Court · [2025] UGHC 349 · 2025 Judgment for Defendant AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
First instance civil suit for trespass, compensation, and injunction arising from destruction of crops and developments on land adjacent to Lake Mulehe
Decision
Suit dismissed — Plaintiffs' claims for trespass, compensation, damages, and injunction refused

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

Held that the Defendant's agents acted lawfully in restoring the buffer zone of Lake Mulehe under constitutional and statutory authority. The Plaintiffs had encroached upon the 100-metre buffer zone required by law, cultivating within 3 to 100 metres of the lakeshore. The Defendant, as custodian of lakeshores under Article 237(2)(b) of the Constitution and the National Environment Regulations 2000, did not require the Plaintiffs' permission to enter the buffer zone. No trespass occurred. The suit was dismissed with each party bearing own costs.

Outcome

Suit dismissed — Plaintiffs' claims for trespass, compensation, damages, and injunction refused

Facts

The Plaintiffs, 50 landowners around Lake Mulehe in Kisoro District, claimed ownership of land and developments including crops, tea estates, and trees. On 11 April 2017, the Defendant's District Environment Officer, accompanied by armed officers and prisoners, entered the land and destroyed the Plaintiffs' crops and developments. The Plaintiffs claimed this was unlawful trespass and sought compensation of UGX 528,570,000, general and aggravated damages, and a permanent injunction. The Defendant contended that the Plaintiffs had encroached upon the statutory 100-metre buffer zone of Lake Mulehe and that the restoration operation was lawful under the Constitution and National Environment Regulations 2000. Evidence at locus in quo revealed that Plaintiffs had left only 3 metres as a buffer zone and that the Defendant's operation extended between 8 and 100 metres from the lakeshore. The Defendant had conducted community engagements prior to the operation and the operation occurred during harvest period, allowing Plaintiffs to mitigate losses.

Issues

  1. Whether the actions of the Defendant's agents were authorized and therefore legal.
  2. Whether the Defendant trespassed on the Suitland.
  3. Whether the Defendant is liable for the acts of its officers.
  4. Whether the Plaintiffs are entitled to any remedies.

Orders

  • Suit dismissed.
  • Each party to bear their own costs.

Rules and key headnotes

Environmental Law — Lakeshores — Buffer Zones — Statutory Protection
Under the National Environment (Wetlands, River Banks and Lakeshores Management) Regulations 2000, lakes not specified in the 7th Schedule are subject to a mandatory 100-metre buffer zone from the lakeshore, which landowners may not cultivate or develop without a licence.
Constitutional Law — Land Ownership — Natural Resources — Government Trusteeship
Article 237(2)(b) of the Constitution charges Government or Local Government to hold in trust for the people and protect natural lakes, rivers, wetlands, and forest reserves for the common good of all citizens, overriding individual land rights within protected zones.
Administrative Law — Local Government Powers — Environmental Protection — Statutory Authority
A Local Government exercising its constitutional and statutory duty to protect lakeshores and restore buffer zones acts with lawful authority and does not require the permission of encroaching landowners to enter the protected zone.
Tort Law — Trespass to Land — Elements — Lawful Authority as Defence
To establish trespass to land, a plaintiff must prove ownership or lawful possession, unauthorized entry by the defendant, and absence of any legal right or authority in the defendant to enter. Where the defendant enters land held in trust for the public under statutory authority, no trespass occurs.
Land & Property — Customary Land Ownership — Limitations — Environmental Protection Zones
Customary land ownership does not confer rights to cultivate or develop land within statutory buffer zones of natural lakes, and such rights are subject to constitutional provisions vesting protection of natural resources in Government or Local Government.

Legislation cited (15)

  • Constitution of Uganda Article 237(1)
  • Constitution of Uganda Article 237(2)(b)
  • Constitution of Uganda Article 245
  • National Environmental Act 1995 Cap 153
  • National Environment (Wetlands, River Banks and Lakeshores Management) Regulations 2000 Regulation 2
  • National Environment (Wetlands, River Banks and Lakeshores Management) Regulations 2000 Regulation 4
  • National Environment (Wetlands, River Banks and Lakeshores Management) Regulations 2000 Regulation 18(2)
  • National Environment (Wetlands, River Banks and Lakeshores Management) Regulations 2000 Regulation 21
  • National Environment (Wetlands, River Banks and Lakeshores Management) Regulations 2000 Regulation 23
  • National Environment (Wetlands, River Banks and Lakeshores Management) Regulations 2000 Regulation 30(1)
  • National Environment (Wetlands, River Banks and Lakeshores Management) Regulations 2000 Regulation 30(2)
  • Evidence Act s.101
  • Evidence Act s.102
  • Evidence Act s.103
  • Evidence Act s.104

Cases cited (2)

  • Justine E.M.N Lutaya v Sterling Civil Engineering Company (SCCA No. 11 of 2002)
  • Sheikh Muhammed Lubowa v Kitara Enterprises (CA No. 4 of 1987)

Full judgment

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

Murenegzi Moses and Others v Kisoro District Local Government (Civil Suit 49 of 2017) [2025] UGHC 349 (10 April 2025)
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.