Osire Charles vs Bukedea District Local Government and another (Miscellaneous Cause No. 8 of 2022)
Observed later treatment
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Holding
The High Court granted the applicant's request for extension of time to file a judicial review application out of time. The applicant had been terminated from employment in February 2020 and travelled to South Sudan intending to return within one month to file judicial review. However, COVID-19 border closures prevented his return until December 2020. The court found that being out of Uganda during the limitation period, combined with financial constraints from job loss and the COVID-19 economic situation, constituted sufficient reason under Rule 5(1) of the Judicature (Judicial Review) Rules to extend time. The respondents failed to contest the application despite service.
Outcome
Applicant granted one month to file judicial review application
Facts
The applicant was terminated from employment on 5 February 2020. On 29 February 2020, he travelled to South Sudan intending to return within one month to file for judicial review of his termination. Due to COVID-19 pandemic border closures at Elegu, he was unable to return to Uganda until 16 December 2020 when he crossed through Owiny-Kibul border. Upon return, he contacted his lawyer who advised him to apply for judicial review out of time. Due to unemployment and the economic situation, it took time to raise funds to file the application. The three-month limitation period under the Judicature (Judicial Review) Rules had expired while he was still in South Sudan. The respondents were served but failed to file any response or appear at multiple scheduled hearings.
Issues
- Whether the applicant has shown sufficient reason to warrant extension of time to file an application for judicial review out of time.
Orders
- Application for extension of time within which to file an application for judicial review out of time is allowed.
- The applicant is given one month to bring his application for judicial review.
- The costs of this application to abide by the main application.
Rules and key headnotes
Legislation cited (8)
- Civil Procedure Act s.96
- Civil Procedure Act s.98
- Civil Procedure Rules Order 51 r.6
- Civil Procedure Rules Order 52 r.1
- Civil Procedure Rules Order 52 r.2
- Judicature (Judicial Review) Rules r.5(1)
- Judicature (Judicial Review) Rules r.5(3)
- Constitution of Uganda Article 126(2)(e)
Cases cited (4)
- I P Mugumya v Attorney General (High Court Miscellaneous Cause No. 116 of 2015)
- Bony M Katatumba v Waheed Karim (Civil Appeal No. 27 of 2007)
- Mugo v Wanjiri [1970] EA 481
- Attorney General v Orient Construction Co. Ltd (Supreme Court Civil Appeal No. 7 of 1990)
Cases citing this judgment (1)
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.