Wakilii

Rex v Kirangi (Criminal Appeal No. 167 of 1940)

East African Court of Appeal · [1940] EACA 24 · 1940 Appeal Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Criminal appeal from conviction for murder in the High Court of Tanganyika
Decision
Conviction for murder upheld

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The Court held that where an accused person receives news that his brother has been killed and then proceeds to where the slayer is already in custody and kills him, there can be no legal provocation within the meaning of section 192 of the Penal Code. A wrongful act or insult done to a person under the accused's care or in a fraternal relation, but not in the accused's presence, does not constitute legal provocation under the express provisions of section 192.

Outcome

Conviction for murder upheld

Facts

The appellant's brother Mushikila was killed in a quarrel by one Lukubalugosa. The appellant was not present at the quarrel or the killing. Upon hearing of his brother's death, the appellant proceeded to the place where Lukubalugosa was held bound and under arrest by the chief. The appellant then clubbed Lukubalugosa to death despite the remonstrances and efforts to prevent him by the tribal police who had Lukubalugosa in custody. The appellant was convicted of murder and appealed on the ground of provocation.

Issues

  1. Whether an act not performed in the presence of the accused may constitute legal provocation within the meaning of section 192 of the Tanganyika Penal Code.

Orders

  • Appeal dismissed.

Rules and key headnotes

Murder — Provocation — Requirements for Legal Provocation
A wrongful act or insult done to a person under the accused's immediate care or to whom the accused stands in a fraternal relation does not constitute legal provocation within the meaning of section 192 of the Penal Code unless the act is done in the presence of the accused.
Murder — Provocation — Killing After News of Brother's Death
Where an accused receives news that his brother has been killed and thereupon proceeds to where the slayer is already in custody and kills him, there can be no question of legal provocation within the meaning of section 192 of the Penal Code.
Murder — Provocation — Distinction from Immediate Retaliation
Legal provocation may be established where an accused acts under the influence of an honest and genuine belief that a wrongful act is being done in his presence to a person under his care and he there and then retaliates, but not where the accused acts after receiving news of a completed wrongful act.

Legislation cited (1)

  • Tanganyika Penal Code s.192

Cases cited (1)

  • R v Okurutumu s/o Ongiro (Criminal Appeal No. 116 of 1938)

Full judgment

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

Rex v Kirangi (Criminal Appeal No. 167 of 1940) [1940] EACA 24 (1 January 1940)
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.