Wakilii

Ojangole & Anor v Jerome Otim (Misc. Applic. 41 of 2013)

High Court · [2014] UGHCCD 40 · 2014 Application Granted AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application to adduce additional evidence arising from civil appeal from land claim
Decision
Applicants granted leave to adduce additional evidence on appeal

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

Held that an affidavit thumb printed by a person who understood its contents raises a presumption of illiteracy, requiring compliance with sections 2 and 3 of the Illiterates Protection Act. Non-compliance renders the affidavit defective. The court allowed additional evidence to be adduced where graves were not visible at trial due to flooding.

Outcome

Applicants granted leave to adduce additional evidence on appeal

Facts

The applicants sought to adduce additional evidence in a civil appeal arising from a land claim. The evidence concerned graves of the second applicant's relatives which could not be seen at trial because floods had covered them. The respondent opposed the application and filed an affidavit in reply sworn by Levi Otim, which was thumb printed and sworn in Lira before an advocate based in Soroti. The applicants challenged the affidavit as defective for non-compliance with the Illiterates Protection Act.

Issues

  1. Whether the applicants should be allowed to adduce additional evidence on appeal.
  2. Whether the affidavit in reply sworn by a thumb print is defective where the deponent did not comply with the Illiterates Protection Act.

Orders

  • Application to adduce additional evidence allowed.
  • Costs in the cause.

Rules and key headnotes

Evidence — Affidavits — Illiterates Protection Act — Thumb printed affidavit — Presumption of illiteracy
Where an affidavit is thumb printed instead of signed by a person who read and understood its contents, the presumption arises that such person is illiterate and the writer of the document must comply with sections 2 and 3 of the Illiterates Protection Act by indicating that the affidavit has been read back to the illiterate; non-compliance renders the affidavit defective.
Civil Procedure — Additional Evidence on Appeal — Legitimate reason — Evidence unavailable at trial
An affirmation that evidence was not seen by the trial court due to circumstances beyond the parties' control constitutes a legitimate reason to allow additional evidence to be adduced on appeal.

Legislation cited (7)

Full judgment

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

Ojangole & Anor v Jerome Otim (Misc. Applic. 41 of 2013) [2014] UGHCCD 40 (15 March 2014)
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.