Nakalyango Fatuma v Electoral Commission (Miscellaneous Cause No. 57 of 2026)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The High Court dismissed the judicial review application for lack of jurisdiction. Where the Constitution provides a statutory right of appeal from Electoral Commission decisions on pre-election complaints under Article 64(1), judicial review is not available unless the applicant first exhausts that alternative remedy. The applicant failed to demonstrate that the statutory appeal was ineffective or that exceptional circumstances existed to bypass it. The Constitution delineates the Electoral Commission as the primary forum for pre-poll electoral disputes, with the High Court exercising supervisory appellate jurisdiction rather than original jurisdiction in such matters.
Outcome
Application dismissed for lack of jurisdiction due to failure to exhaust statutory appeal remedy
Facts
The applicant was nominated as a candidate for Female Youth Councillor to Luwero District Council. On 6 October 2025, a petition was filed challenging her nomination on grounds that she exceeded the youth age bracket. The Electoral Commission invited her for a hearing on 27 October 2025. On 4 December 2025, the Commission de-nominated her, finding that the National Voter's Register showed she was born on 12 January 1986, making her 39 years old and outside the youth age bracket under the National Youth Council Act. The applicant claimed she had evidence from NIRA showing her date of birth as 12 January 1998, placing her within the youth age bracket, but did not adduce this evidence at the Commission hearing. She filed this judicial review application seeking to quash the de-nomination decision and be declared elected unopposed. The respondent objected that the proper remedy was a statutory appeal under Article 64(1) of the Constitution, not judicial review.
Issues
- Whether the High Court has original jurisdiction to entertain a judicial review application challenging an Electoral Commission decision on a pre-election complaint when a statutory right of appeal exists under Article 64(1) of the Constitution.
- Whether the applicant exhausted alternative remedies as required under Rule 7A(b) of the Judicature (Judicial Review) (Amendment) Rules 2019 before seeking judicial review.
- Whether exceptional circumstances exist to justify granting judicial review despite the availability of a statutory appeal remedy.
- Whether the Electoral Commission's decision to de-nominate the applicant was tainted with illegality, irrationality, or procedural impropriety.
Orders
- Application dismissed.
- No order as to costs.
Rules and key headnotes
Legislation cited (20)
- Constitution of Uganda 1995 Article 20
- Constitution of Uganda 1995 Article 38
- Constitution of Uganda 1995 Article 42
- Constitution of Uganda 1995 Article 50
- Constitution of Uganda 1995 Article 60
- Constitution of Uganda 1995 Article 61(1)(f)
- Constitution of Uganda 1995 Article 64(1)
- Constitution of Uganda 1995 Article 139(1)
- Judicature Act Cap 16 s.37
- Judicature Act Cap 16 s.40
- Civil Procedure Act Cap 282 s.98
- Judicature (Judicial Review) Rules SI 11 of 2009 Rule 3
- Judicature (Judicial Review) Rules SI 11 of 2009 Rule 3A
- Judicature (Judicial Review) Rules SI 11 of 2009 Rule 6
- Judicature (Judicial Review) Rules SI 11 of 2009 Rule 7
- Judicature (Judicial Review) Rules SI 11 of 2009 Rule 7A
- Judicature (Judicial Review) (Amendment) Rules 2019 Rule 7A(b)
- Electoral Commission Act s.15
- National Youth Council Act Cap 114 s.1
- National Youth Council Act Cap 114 s.9(3)
Cases cited (19)
- Ssewanyana v Kampala International University (Miscellaneous Cause No. 207 of 2018)
- Town Council of Kikuyu Vs National Social Security & Anor HCT of Kenya at Nairobi Judicial Review Case No 81 of 2013
- Pastoli v Kabale District Local Government Council (2008) 2 EA 300
- Johnas Tweyambe v Attorney General (Miscellaneous Cause No. 395 of 2019)
- Bwowe Ivan v Makerere University (Miscellaneous Cause No. 252 and 265 of 2013)
- Faustine Ntambara v Benon Sebujisho (Civil Appeal No. 08 of 2021)
- Charles Nsubuga v Eng. Badru Kiggundu (Miscellaneous Cause No. 148 of 2025)
- Preston v IRC [1985] 2 All ER 327
- Council of Civil Service Unions v Minister for the Civil Service [1985] AC 374
- Guma Wawa v Attorney General (Miscellaneous Cause No. 164 of 2012)
- Patel v Mussa [2015] All ER (D) 248 (Apr)
- Chapter Four Uganda v National Bureau for Non-Governmental Organisations (Miscellaneous Cause No. 292 of 2021)
- Chief Constable of the North Wales Police v Evans [1982] 3 All ER 141
- Barugahare John Patrick v Mbarara City Council Local Government (Miscellaneous Cause No. 56 of 2022)
- Pius Niwagaba v Law Development Centre (Miscellaneous Cause No. 589 of 2005)
- R (Grace Bay II Holdings SARL) v The Pensions Regulator [2017] EWHC 7 (Admin)
- R (Willford) v FSA [2013] EWCA Civ 677
- R v Epping and Harlow General Commissioners, ex p Goldstraw [1983] 3 All ER 257
- Grace Nalubega v Juliet K. Suubi Kinyamatama (Election Petition Appeal No. 27 of 2021)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.