Wakilii

Nile Breweries Limited v Emmanuel Binyerere (Civil Appeal 56 of 2019)

High Court · [2024] UGHC 18 · 2024 Appeal Abated AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Civil appeal from Chief Magistrate's Court dismissal of claim for recovery of property
Decision
Appeal abated due to death of sole respondent and failure to substitute legal representative

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

Appeal abated under Order 24 Rule 4(3) of the Civil Procedure Rules where the sole respondent died and the appellant failed to make an application to substitute the legal representative of the deceased as a party within the time limited by law, despite being aware of the death and the grant of letters of administration.

Outcome

Appeal abated due to death of sole respondent and failure to substitute legal representative

Facts

Nile Breweries Limited sued Emmanuel Binyerere in the Chief Magistrate's Court of Mbarara claiming two branded coolers it alleged belonged to it and had been stored with its distributor, Muhwezi Mugisha trading as Rugoma Traders, who was the respondent's tenant. The respondent held the coolers when the tenant was shifting premises, contending they belonged to his tenant Tumwine Wilson. The trial magistrate dismissed the suit on 4 October 2019, finding the appellant failed to prove its case and that there was no proper cause of action given the lack of direct relationship between the parties. The appellant appealed. During the appeal proceedings, the respondent died on 23 December 2022. Letters of administration were granted to his estate. The appellant was aware of the death but did not apply under Order 24 Rule 4(1) of the Civil Procedure Rules to substitute the legal representative as a party.

Issues

  1. Whether the appeal abated following the death of the respondent and failure to substitute the legal representative within the time limited by law.

Orders

  • Appeal abates under Order 24 Rule 4(3) of the Civil Procedure Rules.

Rules and key headnotes

Civil Procedure — Abatement — Death of Sole Party — Failure to Substitute Legal Representative
Where a sole party to proceedings dies and the cause of action survives, the suit or appeal shall abate if no application is made within the time limited by law to substitute the legal representative of the deceased as a party to the proceedings.

Legislation cited (1)

Full judgment

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

Nile Breweries Limited v Emmanuel Binyerere (Civil Appeal 56 of 2019) [2024] UGHC 18 (29 January 2024)
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.