Muyanja Shafiq v Matovu Bukenya Livingstone (Miscellaneous Application No. 2056 of 2025)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that where an applicant was in civil prison at the time of the alleged service and hearing of a miscellaneous cause, and there was no evidence of effective service on the officer in charge of the prison as required by Order 5 Rule 19 of the Civil Procedure Rules, the failure to serve constituted sufficient cause to set aside the exparte order. The right to fair hearing under Article 28 of the Constitution is non-derogable and improper service renders any resultant exparte judgment irregular.
Outcome
Exparte order set aside; applicant granted leave to file affidavit in reply and submissions
Facts
The Respondent filed Miscellaneous Cause No. 029 of 2025 seeking a vesting order in respect of land comprised in Kyadondo Block 82 Plot 873. The Applicant was never served with the application. On 24th June 2025, the Applicant was arrested and committed to civil prison arising from Execution Miscellaneous Cause No. 009 of 2023. The hearing of Miscellaneous Cause No. 029 of 2025 was fixed for 24th July 2025 while the Applicant was in prison. The Respondent filed an affidavit of service claiming to have served the Applicant in person on 18th June 2025, which the Applicant denied. The court proceeded exparte and made orders against the Applicant. The Applicant was released from prison on 4th September 2025 and learned of the exparte proceedings from a neighbour. He immediately instructed lawyers and filed this application to set aside the exparte order on grounds of non-service.
Issues
- Whether the Application discloses any sufficient ground for setting aside the exparte order passed by this Honourable Court in Miscellaneous Cause No. 029 of 2025?
Orders
- The Order to proceed exparte against the Applicant in Miscellaneous Cause No. 029 of 2025 is hereby set aside.
- The Applicant is granted leave to file an affidavit in reply to Miscellaneous Cause No. 029 of 2025 and written submissions in reply within two (2) weeks from the date of this ruling.
- The Respondent is directed to file his Affidavit in rejoinder and submissions in rejoinder (if any) within two weeks after the filing of the affidavit in reply and submissions by the Applicant.
- The Court will thereafter deliver its Ruling in Miscellaneous Cause No. 029 of 2025 on notice via ECCMIS.
- The costs of this Application shall be in the main cause.
Rules and key headnotes
Legislation cited (11)
- Civil Procedure Act Cap 282 s.98
- Judicature Act Cap 16 s.37
- Civil Procedure Rules SI 71-1 Order 52 rule 1
- Civil Procedure Rules SI 71-1 Order 52 rule 2
- Civil Procedure Rules SI 71-1 Order 52 rule 3
- Civil Procedure Rules SI 71-1 Order 5 rule 10
- Civil Procedure Rules SI 71-1 Order 49 rule 2
- Civil Procedure Rules SI 71-1 Order 5 rule 19
- Civil Procedure Rules SI 71-1 Order 5 rule 76
- Civil Procedure Rules SI 71-1 Order 9 rule 20(1)(a)
- Constitution of the Republic of Uganda Article 28
Cases cited (7)
- Banco Arabe Esponol Vs Bank of Uganda
- Geoffrey Gatete & Anor Vs William Kyobe
- Vantange Mezzanine Fund II Partnership & Anor v Commissioner Land Registration (HCMA No. 2484 of 2023)
- Mumello v Bank of Tanzania (Civil Appeal No. 12 of 2002)
- Tanga Cement Company Limited v Jumanne D. Masangwa and Amos A. Mwalwanda (Civil Application No. 6 of 2001)
- Lucos Marlsr Vs Uganda Breweries Ltd (1988-1990) HCB I3l
- Remco Ltd Vs. Miistray Jadbra Ltd (2002) (1) E.A Page 233
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.