Namugowa Fred v Maira Daniel Kenneth (Taxation Appeal No. 113 of 2025)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The High Court partly allowed the taxation appeal. The court held that the taxing master was entitled to proceed ex parte where the appellant, after notice, failed to attend pre-taxation without reasonable excuse. The instruction fee was reduced from UGX 3,500,000 to UGX 2,000,000 as the presumed subject matter value did not exceed the Magistrate Grade One Court's pecuniary jurisdiction. Several bill items were set aside or reduced: mediation attendance fees were disallowed as parties bear their own mediation costs; duplicated attendance fees were taxed off; and excessive fees for drawing joint scheduling memoranda and extra copies were reduced.
Outcome
Appeal partly allowed with instruction fee reduced and several bill items set aside or reduced
Facts
The appellant filed a land civil suit (No. 065 of 2019) in the Chief Magistrate Court of Mbale against the respondent, which she subsequently withdrew for lack of jurisdiction. The respondent filed a bill of costs which was taxed on 13 February 2025 in the appellant's absence at UGX 8,547,500. The bill of costs was served on the appellant on 3 July 2024. The matter was adjourned multiple times for pre-taxation, including on 22 October 2024 when it was adjourned to 14 November 2024 for pre-taxation in the presence of the appellant and counsel. On 14 November 2024, the appellant's counsel indicated a need to consent to the bill, and the matter was adjourned to 3 December 2024. However, on that date, both the appellant and counsel were absent despite their promise to pre-tax and consent. The taxing master proceeded ex parte and allowed the bill at UGX 8,547,500. The appellant appealed, challenging the lack of pre-taxation meeting, excessive instruction fees, and various specific items in the bill.
Issues
- Whether the taxing master erred in failing to conduct a pre-taxation meeting before taxing the bill of costs.
- Whether the instruction fee of UGX 3,500,000 was manifestly excessive and inconsistent with taxation principles.
- Whether specific items (39, 41, 49, 50, 51, 52, 55, 56, 57, 58, 65, 66, 67) in the bill of costs were taxed contrary to the Advocates (Remuneration and Taxation of Costs) (Amendment) Regulations 2018.
Orders
- It is declared that the taxing master was right to proceed with the taxation hearing ex parte.
- The bill at UGX 3,500,000 as instruction fee is reduced to UGX 2,000,000.
- The bill at UGX 100,000 as attendance under item 39 is set aside.
- The bill at UGX 150,000 as extra copies for drawing 3 copies of written statement of defence under item 41 is reduced to UGX 100,000.
- The bill taxed under items 50, 51, 52 and 53 is set aside.
- The bill taxed under items 49, 55, 56, 57 and 58 is maintained.
- The bill at UGX 300,000 under item 65 is reduced to UGX 200,000.
- The bill at UGX 150,000 under item 66 is reduced to UGX 100,000.
- The bill taxed under item 67 is maintained.
- Each party shall bear its own costs.
Rules and key headnotes
Legislation cited (10)
- Advocates Act Cap 259 s.68(1)
- Civil Procedure Act Cap 282 s.98
- Judicature Act Cap 16 s.37
- Advocates (Taxation of Costs) (Appeal and References) Regulations SI.267-5 Regulation 3
- Advocates (Remuneration and Taxation of Costs) Regulations 2018 Regulation 9
- Advocates (Remuneration and Taxation of Costs) Regulations 2018 Regulation 13(a)
- Advocates (Remuneration and Taxation of Costs) Regulations 2018 Regulation 11
- Advocates (Remuneration and Taxation of Costs) (Amendment) Regulations 2018 6th Schedule Paragraph 1(1)(d)
- Advocates (Remuneration and Taxation of Costs) (Amendment) Regulations 2018 Regulation 10
- Judicature (Mediation) Rules 2013 Rule 20(1)
Cases cited (2)
- Joreth Ltd v Kigano & Associates [2002] 1 EA 92
- Vantage Mezzanine Fund II Partnership v Simba Properties Investment Co. Limited & 5 others (Taxation Appeal No. 14 of 2024)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.