Wakilii

Nyabwolo Owino v Oketch and 2 Others (Miscellaneous Application No. 0087 of 2024)

High Court · [2025] UGHC 906 · 2025 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for review of High Court judgment dismissing civil suit on preliminary objections
Decision
Application for review dismissed; applicant may file a proper suit subject to limitation

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

Held that an applicant seeking review under Section 82 of the Civil Procedure Act must be an aggrieved person who has suffered a legal grievance involving loss of a right or title. Where a suit was dismissed on preliminary objections without determining the merits, the applicant suffered no legal grievance as she remains free to file a proper suit subject to limitation. The application for review was dismissed.

Outcome

Application for review dismissed; applicant may file a proper suit subject to limitation

Facts

The applicant, claiming to be administratrix of the estate of the late Rev. Fr. Gabriel William Owino, filed a civil suit against the respondents claiming trespass to land and recovery of land at Paponyi A Village, Tororo District. At the hearing, the respondents raised preliminary objections that she lacked locus standi and that her plaint disclosed no cause of action. Both preliminary objections were sustained and the suit was dismissed with costs. The applicant then sought review of the dismissal order, grounding her application on discovery of new and important evidence and error apparent on the face of the record.

Issues

  1. Whether the applicant has sufficient grounds for review?
  2. Whether there are any available remedies?

Orders

  • Application dismissed.
  • Costs awarded to the respondents.

Rules and key headnotes

Civil Procedure — Review — Locus Standi — Aggrieved Person
An applicant seeking review under Section 82 of the Civil Procedure Act must be a person who has suffered a legal grievance as a result of a court's decision, order or decree, and such legal grievance must involve loss of a right in something or title in property.
Civil Procedure — Review — Dismissal on Preliminary Objections — No Legal Grievance
Where a suit is dismissed on preliminary objections without determining the merits, the applicant suffers no legal grievance for purposes of review because the dismissal does not determine loss of right or title in property and the applicant remains free to file a proper suit subject to the law of limitation.

Legislation cited (6)

Cases cited (4)

  • A Muhammed Allibhai v W.E. Bukenya and DAPCB (Supreme Court Civil Appeal No. 56 of 1996)
  • Busoga Growers Co-operative Union Ltd v Nsamba & Sons Ltd (High Court Miscellaneous Application No. 123 of 2000)
  • Re Nakivubo Chemists (U) Ltd (1979) HCB 12
  • Ladak Abdallah Mohammed Hussein v Isingoma Kakiiza (Supreme Court Civil Appeal No. 8 of 1995)

Full judgment

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

Nyabwolo Owino v Oketch and 2 Others (Miscellaneous Application No. 0087 of 2024) [2025] UGHC 906 (10 September 2025)
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.