Wakilii

Musiime Alex alias Kadidi v Uganda (HCT-05-CR-MA-0004-2004)

High Court · [2004] UGHC 87 · 2004 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for bail arising from criminal committal proceedings
Decision
Bail application dismissed with order for applicant to access medical services while on remand

Observed later treatment

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Holding

Held that section 15 of the Trial on Indictments Act requires certification of grave illness by a medical officer of the prison or institution where the accused is detained, and no one else. The affidavit of a person in charge of health matters at the prison who is not a medical officer does not satisfy the statutory requirement. The court ordered prison authorities to allow the applicant access to his personal doctor and denied the bail application.

Outcome

Bail application dismissed with order for applicant to access medical services while on remand

Facts

The applicant Musiime Alex alias Kadidi had been on remand since 24 September 2003. He applied for bail under Article 23 of the Constitution, arguing that exceptional circumstances existed due to his grave illness, namely peptic ulcers and asthma. He relied on section 15 of the Trial on Indictments Act which provides for bail where an accused suffers from grave illness and cannot receive adequate medical treatment in custody. Two affidavits were filed: one by Ms Achieng, described as in charge of health matters at Mbarara Prison, and another by Dr. Luwala, the applicant's personal doctor since 1996, who certified that the applicant suffered from grave illness requiring constant medical attention which could not be provided in prison due to lack of ready access to the doctor.

Issues

  1. Whether the applicant qualified for bail on the ground of grave illness under section 15 of the Trial on Indictments Act.
  2. Whether a person other than a medical officer of the prison could certify grave illness for purposes of bail.
  3. Whether the applicant should be granted access to his personal doctor while on remand.

Orders

  • Prison authorities ordered to allow the applicant to summon and receive the services of his personal doctor without let or hindrance.
  • Application for bail dismissed.

Rules and key headnotes

Bail — Grave Illness — Statutory Certification Requirements
Section 15 of the Trial on Indictments Act requires that an accused suffering from grave illness must be certified by a medical officer of the prison or other institution where the accused is detained as being incapable of adequate medical treatment while in custody. A person in charge of health matters at a prison who is not a medical officer cannot provide the statutory certification.
Medical Evidence — Certification by Personal Doctor — Statutory Requirements
Where a statute prescribes that certification of grave illness must come from a medical officer of the institution where an accused is detained, certification by the accused's personal doctor, though qualified as a medical practitioner, does not satisfy the statutory requirement if that doctor is not a medical officer of the prison or detention facility.
Remand — Access to Medical Treatment — Prisoner's Rights
A court may order prison authorities to allow an accused person on remand to summon and receive the services of his personal doctor without hindrance in order to alleviate medical circumstances, even where the requirements for bail on medical grounds are not met.

Legislation cited (2)

Full judgment

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

Musiime Alex alias Kadidi v Uganda (HCT-05-CR-MA-0004-2004) [2004] UGHC 87 (10 March 2004)
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.