National Resistance Movement v Kampala Modernity Printers Ltd (Miscellaneous Appeal No. 6 of 2016)
Observed later treatment
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Holding
Held that while the proper procedure for challenging a registrar's judgment on admission is by application to set aside under Order 9 rule 12 rather than by appeal under Order 50 rule 8, the procedural irregularity is not fatal where the court has jurisdiction, no prejudice has been occasioned, and the notice of motion seeks the same relief. The court applied Article 126(2)(e) of the Constitution to administer substantive justice without undue regard to technicalities, finding that procedural rules are handmaidens of justice. The preliminary objection was dismissed.
Outcome
Preliminary objection dismissed; matter to proceed to determination on the merits
Facts
The Appellant filed a notice of motion styled as an appeal from a registrar's judgment on admission entered on 29 January 2016 under Order 13 rule 6 of the Civil Procedure Rules in HCCS No. 50 of 2013. The registrar had entered judgment on admission against the Appellant. The Respondent raised a preliminary objection that the matter should have been brought by way of an application to set aside the ex parte judgment under Order 9 rule 12 or rule 27, rather than by appeal under Order 50 rule 8. The Respondent argued that there is a dedicated procedure for challenging registrar's judgments on admission and that appeals under Order 50 rule 8 do not lie from such judgments. The Appellant contended that a judgment on admission has finality and the only route open is to appeal it under Order 50 rule 8.
Issues
- Whether an appeal lies from a registrar's judgment on admission entered under Order 13 rule 6 of the Civil Procedure Rules.
- Whether the proper procedure for challenging a registrar's judgment on admission is by way of appeal under Order 50 rule 8 or by application to set aside under Order 9 rule 12 of the Civil Procedure Rules.
- Whether the appeal as filed is competent or should be dismissed for failure to follow the prescribed procedure.
Orders
- Preliminary objection dismissed with costs.
- The court treated the notice of motion styled as an appeal as an application to set aside judgment under Order 9 rule 12 of the Civil Procedure Rules.
- Matter allowed to proceed on its merits.
Rules and key headnotes
Legislation cited (35)
- Constitution of the Republic of Uganda 1995 art.126(2)(e)
- Constitution of the Republic of Uganda 1995 art.129
- Constitution of the Republic of Uganda 1995 art.133
- Constitution of the Republic of Uganda 1995 art.139
- Constitution of the Republic of Uganda 1995 art.145
- Constitution of the Republic of Uganda 1995 art.257
- Judicature Act cap 13 s.14
- Judicature Act cap 13 s.16
- Judicature Act cap 13 s.43
- Civil Procedure Act s.57
- Civil Procedure Act s.66
- Civil Procedure Act s.67
- Civil Procedure Act s.79
- Civil Procedure Act s.98
- Civil Procedure Rules Order 9 r.6
- Civil Procedure Rules Order 9 r.7
- Civil Procedure Rules Order 9 r.8
- Civil Procedure Rules Order 9 r.9
- Civil Procedure Rules Order 9 r.10
- Civil Procedure Rules Order 9 r.12
- Civil Procedure Rules Order 9 r.27
- Civil Procedure Rules Order 13 r.6
- Civil Procedure Rules Order 43 r.1
- Civil Procedure Rules Order 50 r.1
- Civil Procedure Rules Order 50 r.2
- Civil Procedure Rules Order 50 r.3
- Civil Procedure Rules Order 50 r.4
- Civil Procedure Rules Order 50 r.5
- Civil Procedure Rules Order 50 r.8
- Civil Procedure Rules Order 50 r.10
- Civil Procedure Rules Order 52 r.1
- Civil Procedure Rules Order 52 r.3
- Evidence Act s.57
- Interpretation Act cap 3 s.18(4)
- Judicial Powers of Registrars Practice Direction No. 1 of 2003
Cases cited (16)
- Nicholas Roussos v Ghulam Hussein Habib Virani and another (SCCA No. 9 of 1993)
- Speaker of National Assembly v Karume Court of Appeal of Nairobi (Volume 1 Kenya Law Reports 2008 at 425)
- Attorney General v James Mark Kamoga and another (supra)
- Kimani v McConnell [1966] EA 547
- Mbogo v Shah [1968] EA 93
- Kafeero v Standard Bank [1970] EA 465
- Patel v EA Cargo Handling Services [1974] EA 75
- Attorney General and Uganda Land Commission v James Mark Kamoga and James Kamala (SCCA No. 8 of 2004)
- Speaker of the National Assembly v Karume Court of Appeal Civil Appeal No. NAI 92 of 1992
- Magem Enterprises Ltd v Uganda Breweries Ltd (HCCS No. 462 of 1991)
- Saggu v Roadmaster Cycles (U) Ltd [2002] 1 EA 258
- Nanjibhi Prabhudas and Company Limited v Standard Bank Limited [1968] EA
- Re Christine Namatovu Tebajjukira [1992-93] HCB 85
- Adonia v Mutekanga [1970] EA 429
- Rawal v Mombasa Hardware Ltd [1968] EA 392
- Boyes v Gathure [1969] 1 EA 385
Cases citing this judgment (1)
How later Ugandan judgments in the Wakilii corpus have cited this case. Treatment labels come from Sequitur — Uganda’s citator — each backed by a verbatim span from the citing judgment, and are not an assertion that this case is, or is not, good law.
Full judgment
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