Open Forum Initiative[TOFI] v Attorney General of Uganda and Another (Miscellaneous Cause No. 251 of 2020)
Observed later treatment
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Holding
An application for judicial review filed six months after the statutory three-month period cannot be extended on the ground of Covid-19 lockdown restrictions where court registries remained open and restrictions were lifted within the prescribed time. Time limits for judicial review are matters of substantive law that must be strictly complied with. Additionally, Uganda Revenue Authority was not a proper or necessary party to a challenge against regulations made by the Minister of Finance, as it was merely the implementing agency and not responsible for making the impugned regulations.
Outcome
Application for judicial review dismissed for being time-barred and for misjoinder of parties
Facts
The Open Forum Initiative sought judicial review of the Income Tax (Rental Rates) Regulations 2020, published on 13 March 2020, arguing that the Minister of Finance made them without Parliamentary approval as required by section 5(6) of the Income Tax Act. The applicant filed on 7 September 2020, six months after the statutory three-month period for judicial review applications, seeking both extension of time and substantive remedies. The applicant claimed it could not access the Regulations during the Covid-19 lockdown that began in March 2020 and was only able to review them after restrictions eased in June 2020. The applicant sued both the Attorney General and Uganda Revenue Authority, seeking orders of certiorari, prohibition, and mandamus.
Issues
- Whether the time within which to file the application for judicial review should be extended.
- Whether the 2nd Respondent is the wrong party to the judicial review application.
Orders
- Application dismissed.
- Costs awarded to the Respondents.
Rules and key headnotes
Legislation cited (13)
- Constitution of Uganda Article 43
- Constitution of Uganda Article 152
- Judicature Act s.33
- Judicature Act s.36
- Civil Procedure Act s.98
- Judicature (Judicial Review) Rules Rule 3(1)
- Judicature (Judicial Review) Rules Rule 5(1)
- Income Tax Act Cap 340 s.5
- Income Tax Act Cap 340 s.5(6)
- Income Tax Act Cap 340 s.164
- Income Tax (Amendment) Act 2017/2018 s.3
- Uganda Revenue Authority Act s.3
- Income Tax (Rental Rates) Regulations 2020 S.I. No. 42 of 2020
Cases cited (9)
- Uganda Revenue Authority v Uganda Consolidated Properties Ltd (Civil Appeal No. 31 of 2000)
- Okoth Umaru and 3 Others v Busia Municipal Council and 3 Others (HCMC No. 12 of 2016)
- Prime Contractors Ltd v PDA and Others (HC Miscellaneous Cause No. 91 of 2004)
- Kampala University v National Council for Higher Education (Miscellaneous Cause No. 53 of 2014)
- Re Application by Mustapha Ramathan (Civil Appeal No. 25 of 1996)
- IP Mugumya v Attorney General (HCMC No. 116 of 2015)
- Enterprise Inns Plc v Secretary of State for the Environment, Transport and the Regions (2001) 81 P.&C.R. 18
- O'Reilly v Mackman [1983] 2 AC 237 at 280
- Hardy v Pembrokeshire County Council [2006] EWCA Civ 240, [2006] Env LR 28
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
The original judgment as reported. Read the original PDF before relying on any passage.