Wakilii

No.441 P.C Ismail Kisegerwa & anoer v Uganda (Cr.Appeal No.6 of 1978)

Court of Appeal · [1978] UGCA 6 · 1978 Appeal Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Criminal appeal from High Court conviction for manslaughter and sentence
Decision
Appeals of both appellants dismissed; convictions and 15-year sentences for manslaughter upheld

Observed later treatment

Cited — treatment unverified cited in 2 (treatment unverified) Sequitur — Uganda’s citator · Derived from citing cases in the Wakilii corpus — not an assertion that this case is good law.

Citator coverage is limited to judgments in the Wakilii corpus and source-matched treatment records. Absence of a signal is not an assertion that the case remains good law.

No adverse treatment recorded Cited 2 times with no adverse treatment recorded; not yet tested on the merits. Citations rising — 3 citing cases on record, 3 in the most recent three data years. Derived from citing cases in the Wakilii corpus — a deterministic signal, not legal advice.

AI-generated summary. This summary was generated by AI from the full text of the judgment. It may contain errors or omissions—always read the source judgment before relying on it.

Holding

The Court of Appeal dismissed the appeals of two police officers convicted of manslaughter after shooting dead an unarmed suspect fleeing arrest. It held that killing to effect arrest is justified only where there is an apparent necessity; here the suspects were unarmed, posed no danger, and no property was at risk, so the force was unreasonable and excessive. Applying s.22 of the Penal Code, the Court held that the doctrine of common intention applied since both appellants fired in pursuit of an unlawful common purpose that developed in the course of events, making it unnecessary to determine which shot killed the deceased. The Court upheld the 15-year sentence as neither harsh nor excessive.

Outcome

Appeals of both appellants dismissed; convictions and 15-year sentences for manslaughter upheld

Facts

On 6th March 1976, the two appellants, police officers attached to the Naguru Public Safety Unit, were on night patrol, each armed with a self-loading rifle and 20 rounds of ammunition. Near 3 a.m. at Wandegeya they saw two men standing at the door of a house and suspected they were about to commit burglary. As the officers stopped and reversed their vehicle, the two men ran. The appellants gave chase and opened fire, killing one of them, a Makerere Law student named Paul Serwanga. Each appellant admitted firing one shot; one aimed at the legs, the other claimed his gun went off accidentally. It could not be established whose shot killed the deceased. Examination of the door revealed no signs of breaking; the suspects were unarmed and carried no weapons or house-breaking instruments, and the officers' lives were not in danger. Medical evidence showed the deceased was shot at close range. The appellants raised a defence of justifiable homicide, which the trial judge rejected, convicting them of manslaughter.

Issues

  1. Whether the force used by the police officer appellants in effecting arrest was reasonable, and if not, whether the killing amounted to murder or manslaughter.
  2. Whether the doctrine of common intention under s.22 of the Penal Code applied where both appellants fired but it could not be established whose shot killed the deceased.
  3. Whether the trial judge was required to make a finding as to which appellant fired the fatal shot before convicting both of manslaughter.
  4. Whether the sentence of 15 years' imprisonment was harsh and excessive.

Orders

  • The appeal of each appellant is dismissed.
  • Conviction for manslaughter upheld.
  • Sentence of 15 years' imprisonment upheld.

Rules and key headnotes

Homicide — Use of Force in Effecting Arrest — Apparent Necessity
A killing in the course of preventing crime or arresting offenders is justified only where there is an apparent necessity to do so; where the suspects are unarmed, pose no danger to life or property, and there is no reasonable necessity for lethal force, the force used is unreasonable and excessive.
Homicide — Excessive Force in Arrest — Murder or Manslaughter
Where excessive force is used in effecting an arrest and death ensues, the killing constitutes murder or manslaughter depending on whether malice aforethought is present; absent malice, the offence is manslaughter.
Common Intention — Development in Course of Events — Section 22 Penal Code
Under s.22 of the Penal Code, common intention to pursue an unlawful purpose need not exist from the outset nor arise from a prearranged plan; it may develop in the course of events, and it is immaterial that the original common intention was lawful so long as an unlawful purpose develops.
Common Intention — Fatal Act by One of Several Participants
Where the doctrine of common intention applies, it is not necessary to determine which participant actually caused the death; each participant in the unlawful common purpose is liable for the resulting offence.

Legislation cited (2)

Cases cited (7)

  • Muhidini -vs- R [1962] E.A. at p.388
  • R vs- Tabulayenka s/o Kirya and Others [1943] 10 E.A.C.A. 51
  • Andrea Mutebi and Anor -vs- Uganda Cr. App. 144/75 E.A.C.A
  • P -vs- Okute [1941] 8 E.A.C.A. at p.80
  • Wanjiro Wamiro -vs-R [1955] 22 E.A.C.A. 521 at p.52
  • R -vs- Salmon [1880] 6 Q.B 79, C.C.R.
  • Gitau -vs- R [1967] E.A. 449

Cases citing this judgment (2)

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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No.441 P.C Ismail Kisegerwa & anoer v Uganda (Cr.Appeal No.6 of 1978) [1978] UGCA 6 (19 December 1978)
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.