Wakilii

Ratidu Trading Ltd and Another v Equity Bank (U) Ltd (Miscellaneous Application 2561 of 2025)

High Court · [2026] UGCOMMC 132 · 2026 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for stay of execution of orders dismissing a review application, pending appeal to the Court of Appeal
Decision
Application for stay of execution dismissed; applicants' purported appeal declared procedurally incompetent for lack of leave to appeal

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The court dismissed the application for stay of execution. The order dismissing the review application was a negative order incapable of execution, and therefore not amenable to a stay. The order for costs, though executable, did not meet the threshold for substantial loss. Critically, the applicants' notice of appeal was incompetent because an appeal from an order dismissing a review application requires leave of court under section 76 of the Civil Procedure Act and Order 44 rule 2 of the Civil Procedure Rules, which the applicants had not obtained.

Outcome

Application for stay of execution dismissed; applicants' purported appeal declared procedurally incompetent for lack of leave to appeal

Facts

The respondent bank obtained default judgment against the applicants in Civil Suit No. 1102 of 2023 for recovery of UGX 1,317,881,432.26 after the applicants failed to secure leave to defend. The applicants then filed Miscellaneous Application No. 0940 of 2025 seeking review and setting aside of the judgment, claiming their former counsel negligently failed to attach proof of payment of UGX 700,000,000. The review application was dismissed on 25 August 2025. The applicants filed a notice of appeal to the Court of Appeal (Civil Appeal No. 0626 of 2025) and then brought this application seeking stay of execution of the orders dismissing the review application, pending determination of their appeal. The applicants claimed the respondent had commenced execution proceedings and that they would suffer substantial loss including collapse of their business and sale of properties worth over UGX 10 billion. The respondent opposed, arguing the dismissal order was a negative order incapable of execution and that the applicants' appeal was incompetent because they had not obtained the required leave to appeal from an order dismissing a review application.

Issues

  1. Whether the application for stay of execution pending appeal should be allowed.

Orders

  • Application dismissed.
  • Costs awarded to the respondent.

Rules and key headnotes

Civil Procedure — Stay of Execution — Negative Orders — Dismissal of Review Application
An order dismissing an application for review is a negative order which is incapable of execution and therefore not amenable to an order of stay of execution. Such an order requires no enforcement machinery to take effect.
Civil Procedure — Appeals — Leave to Appeal — Review Applications
Under section 76 of the Civil Procedure Act and Order 44 rule 2 of the Civil Procedure Rules, an appeal from an order dismissing an application for review does not lie except with leave of court. A notice of appeal filed without the requisite leave is a nullity and cannot form the basis of an application for stay of execution.
Civil Procedure — Stay of Execution — Costs Orders — Substantial Loss
An order for costs is a positive order capable of execution upon taxation. However, applicants seeking stay of execution of a costs order must demonstrate that taxation or subsequent execution would occasion substantial loss. Apprehension of financial inconvenience, without more, does not meet the evidential threshold where amounts due can be quantified and recovered in the ordinary course of execution.

Legislation cited (9)

Cases cited (5)

  • Lawrence Musiitwa Kyazze v Eunice Busingye (Supreme Court Civil Appeal No. 18 of 1990)
  • Kyambogo University v Prof Isiah Omolo Ndiege (Court of Appeal Miscellaneous Application No. 341 of 2013)
  • Finasi/Roko Construction SPV (LTD) and Another v Finasi International FZC (Civil Application No. 220 of 2019)
  • Exclusive Estate Limited V Kenya Posts and Telecommunications Corporation and Another [2005] 1 EA 53 (CA)
  • Dr Ahmed Mohhamad Kisule v Greenland Bank (In Liquidation) (Supreme Court Civil Appeal No. 7 of 2010)

Full judgment

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

Ratidu Trading Ltd and Another v Equity Bank (U) Ltd (Miscellaneous Application 2561 of 2025) [2026] UGCommC 132 (19 April 2026)
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.