Wakilii

Nankindu v Uganda (Criminal Appeal 66 of 2020)

High Court · [2021] UGHCCRD 61 · 2021 Appeal Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Criminal appeal from Magistrate Grade I ruling on amendment of charge sheet
Decision
Appeal dismissed for lack of jurisdiction to hear interlocutory appeals

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The High Court held that there is no right of appeal against interlocutory rulings in criminal trials under the Magistrates Courts Act. Section 204 provides for appeals only against final orders of conviction or acquittal. A ruling allowing amendment of a charge sheet is interlocutory and does not constitute a final resolution of the controversy. Appeal is a creature of statute and cannot be conferred by litigants or the court where the statute does not provide for it.

Outcome

Appeal dismissed for lack of jurisdiction to hear interlocutory appeals

Facts

The appellant was charged before Kajjansi Magistrates Court. On 30 September 2020, the prosecution applied to amend the charge sheet. The appellant's counsel objected on the ground that the prosecution had not sought leave of court or heard from the defence before making the amendment. The trial magistrate ruled that no provision required leave and dismissed the objection. The appellant appealed against that ruling to the High Court, arguing that the charge sheet should not have been amended without leave of court.

Issues

  1. Whether there is a right of appeal against an interlocutory ruling in criminal proceedings before a magistrate's court.

Orders

  • Appeal dismissed.

Rules and key headnotes

Criminal Law & Procedure — Appeals — Interlocutory Orders — Right of Appeal
There is no right of appeal against interlocutory rulings in criminal trials before magistrates' courts. Section 204 of the Magistrates Courts Act provides for appeals only against final orders of conviction or acquittal, not against interim or procedural rulings made during the course of trial.
Statutory Interpretation — Appeals — Creature of Statute
Appeal is a creature of statute. Neither litigants nor the court can confer a right of appeal where the enabling statute does not provide for it. The right to appeal must be expressly granted by legislation.
Criminal Law & Procedure — Interlocutory Orders — Definition and Treatment
An interlocutory order is one that is interim or temporary and does not constitute a final resolution of the whole controversy. A ruling allowing amendment of a charge sheet is interlocutory in nature as it does not determine the matter finally. Complaints about such rulings should be raised on appeal at the conclusion of the trial.

Legislation cited (1)

Cases cited (1)

  • Twagira v Uganda [2003] 2 EA 689

Full judgment

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

Nankindu v Uganda (Criminal Appeal 66 of 2020) [2021] UGHCCRD 61 (4 August 2021)
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.