Wakilii

Rex v Luzala (Cr.A. 158-33.)

East African Court of Appeal · [1937] EACA 106 · 1937 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for leave to appeal against refusal by Supreme Court of Kenya judge to grant certificate under section 364(b) Criminal Procedure Code
Decision
Application dismissed; murder conviction stands

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The Court of Appeal held that a trial judge's one-word written judgment followed by reasons written a month later did not comply with sections 163 and 164 of the Criminal Procedure Code. However, the application for leave to appeal was dismissed because the evidence was such that murder was the only reasonable finding. The Court stated that judges should write and deliver reasons at the time of judgment and should note points put to assessors in summing up.

Outcome

Application dismissed; murder conviction stands

Facts

The appellant was convicted of murder by the Supreme Court of Kenya. At the conclusion of trial, the trial judge took the assessors' opinion and wrote only the word 'Judgment: Murder'. One month later, the judge wrote his reasons for the judgment. The appellant sought leave to appeal against the refusal of a certificate under section 364(b) of the Criminal Procedure Code, arguing that the judgment did not comply with statutory requirements for written reasons.

Issues

  1. Whether the trial judge's written judgment complied with sections 163 and 164 of the Criminal Procedure Code.
  2. Whether the evidence was of such a nature that the murder conviction was the only reasonable finding.

Orders

  • Application for leave to appeal dismissed.

Rules and key headnotes

Criminal Procedure — Judgment — Requirement to Write and Deliver Reasons
The reasons for a judgment should be written and read at the time of delivering judgment, not written substantially later.
Criminal Procedure — Judgment — Compliance with Sections 163 and 164
A trial judge's utterance of a one-word judgment followed by reasons written a month later does not constitute sufficient compliance with sections 163 and 164 of the Criminal Procedure Code.
Criminal Procedure — Summing Up to Assessors — Record-Keeping
In all but the clearest cases, the trial judge should make a note of the points put to the assessors in the summing up and of the evidence stated as supporting or otherwise each point.

Legislation cited (3)

  • Criminal Procedure Code s.163
  • Criminal Procedure Code s.164
  • Criminal Procedure Code s.364(b)

Full judgment

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

Rex v Luzala (Cr.A. 158-33.) [1937] EACA 106 (1 January 1937)
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.