Murisho Shafi v Jinja City Council (Miscellaneous Cause No. 2 of 2025)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that the application was filed within time, as the cause of action arose when the respondent failed to swear in the applicant on December 17, 2024, after demand. The respondent, as a statutory local government authority, is subject to judicial review. The respondent's refusal to swear in the applicant without affording him a fair hearing and while treating the Solicitor General's non-binding opinion as determinative was procedurally improper and unlawful. Mandamus issued directing the respondent to either swear in the applicant or subject any adverse decision to a lawful and fair process within sixty days.
Outcome
Mandamus issued directing respondent to swear in applicant or afford him due process within sixty days
Facts
On July 25, 2024, the applicant was approved as Chairperson of the Area Land Committee for Jinja Southern Division by the Southern Division council. On October 24, 2024, Jinja City Council approved the applicant and other committee members. The applicant was invited to a swearing-in ceremony scheduled for November 22, 2024, which was postponed due to a complaint. The Solicitor General issued an initial opinion on November 19, 2024, stating that the applicant's previous service in the defunct Jinja Central Division did not disqualify him. A second swearing-in was scheduled for December 17, 2024. However, on December 9, 2024, the Solicitor General issued a clarifying opinion stating that the applicant's past record disqualified him. The applicant's lawyers demanded on December 14, 2024, that the respondent proceed with the swearing-in, but the respondent neither responded nor conducted the ceremony on December 17, 2024.
Issues
- Whether the application was properly before the court within the time limits prescribed by the Judicature (Judicial Review) Rules.
- Whether the impugned conduct of the respondent is subject to judicial review.
- Whether the applicant is entitled to the remedies requested.
Orders
- A declaration is issued that the Respondent's refusal and/or failure to swear in the Applicant as Chairperson of the Area Land Committee for Jinja Southern Division, despite the appointment shown in the Respondent's own records and invitations, and without providing him with due process, was unlawful and procedurally wrong.
- An order of mandamus is issued directing the Respondent and its relevant officials to take all lawful steps necessary within sixty days from the date of this ruling, either to swear in the Applicant in accordance with the approvals already communicated or, if the Respondent still intends to act adversely against him due to complaints or alleged disqualification, to first subject that issue to a lawful, fair, and transparent process in accordance with the applicable law and the rules of natural justice.
- The Respondent shall bear the costs of this application.
Rules and key headnotes
Legislation cited (16)
- Judicature Act s.36
- Judicature Act s.37
- Judicature Act s.38
- Civil Procedure Act s.98
- Judicature (Judicial Review) Rules 2009 r.3
- Judicature (Judicial Review) Rules 2009 r.6
- Judicature (Judicial Review) Rules 2009 r.5(1)
- Judicature (Judicial Review) Rules 2009 r.2
- Judicature (Judicial Review) Rules 2009 r.7A(1)
- Judicature (Judicial Review) Rules 2009 r.7A(2)
- Judicature (Judicial Review) Rules 2009 r.1A
- Judicature (Judicial Review) Rules 2009 r.8
- Land Act s.66(1)
- Local Governments Act Cap. 138 s.3
- Local Governments Act Cap. 138 s.4
- Local Governments Act Cap. 138 s.6(1)
Cases cited (4)
- Hon. Theodore Ssekikubo & Others v Attorney General & Others (Constitutional Appeal No. 1 of 2015)
- Mulisa v The Commissioner Land Registration & Others (Miscellaneous Cause No. 281 of 2022)
- R v Electricity Commissioners, ex parte London Electricity Joint Committee Co (1924) 1 KB 171
- Marbury v Madison, 5 US (1 Cranch) 137 (1803)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.