Royal Electronics Assembling Group Limited v Uganda Revenue Authority (Miscellaneous Application 208 of 2024)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that failure by the Court to communicate a hearing date to counsel who was not linked to the Electronic Court Case Management Information System (ECCMIS) constituted sufficient cause for non-appearance under Order 43 Rule 16 of the Civil Procedure Rules. A litigant should not bear the consequences of counsel's default where the default results from systemic factors beyond counsel's control. The dismissal order was set aside and the appeal reinstated.
Outcome
Appeal reinstated for hearing on merits
Facts
The Applicant lodged an appeal in the High Court on 30 June 2020 against a Tax Appeals Tribunal decision. The Applicant extracted hearing notices for 3 December 2021 and 7 September 2022, but the matter did not proceed on either date. The Court Clerk informed the Applicant that a new date would be communicated. The appeal was scheduled for 12 July 2023 and dismissed for non-attendance. The Applicant's counsel was not linked to the Electronic Court Case Management Information System (ECCMIS) when cases were migrated to the system in 2021, and therefore did not receive the hearing notice issued on 12 July 2023. Counsel was only linked to ECCMIS on 9 February 2024 when filing this application.
Issues
- Whether the Applicant was prevented by sufficient cause from appearing when Civil Appeal No. 0038 of 2020 was called on for hearing?
- What remedies are available?
Orders
- The dismissal order in Civil Appeal No. 0038 of 2020 is set aside.
- Civil Appeal No. 0038 of 2020 is reinstated to be heard on its merits.
- No order as to costs.
Rules and key headnotes
Legislation cited (9)
- Judicature Act Cap 16 s.14(1)
- Civil Procedure Act Cap 282 s.98
- Civil Procedure Rules S.I 71-1 Order 43 Rule 14(1)
- Civil Procedure Rules S.I 71-1 Order 43 Rule 16
- Civil Procedure Rules S.I 71-1 Order 52 Rule 1
- Civil Procedure Rules S.I 71-1 Order 52 Rule 3
- Civil Procedure Rules S.I 71-1 Order 15 Rule 3
- Evidence Act Cap 8 s.101
- Evidence Act Cap 8 s.103
Cases cited (6)
- Bishop Jacinto Kibuuka v Uganda Catholic Lawyers Society and 2 Others (Miscellaneous Application No. 696 of 2018)
- Goldmine Finance Limited v Kato (Miscellaneous Application No. 2896 of 2023)
- Ongom v Nyero (Civil Appeal No. 14 of 2001)
- Banco Arabe Espanol v Bank of Uganda (Civil Appeal No. 8 of 1998)
- Florence Nabatanzi v Naome Binsobedde (Supreme Court Civil Appeal No. 6 of 1987)
- Jovelyn Barugahare v Attorney General (Supreme Court Civil Appeal No. 28 of 1993)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.