Wakilii

Sam Ssensalire v Uganda (Criminal Miscellaneous Application 236 of 2026)

High Court · [2026] UGHCCRD 66 · 2026 Application Granted AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for extension of time to lodge a criminal appeal against a trial court conviction
Decision
Application allowed; time to lodge the notice and memorandum of appeal extended under section 28(6) of the Criminal Procedure Code Act.

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The applicant, convicted and imprisoned, sought an extension of time to appeal under section 28(6) of the Criminal Procedure Code Act. The court held that good cause must relate to the applicant's inability to take the required step within time, not merely to the sympathy his position attracts or the arguability of the intended appeal. Indigence and incarceration operating together upon an unrepresented convict were capable of amounting to good cause, and did so on the facts. The State's non-opposition did not confer jurisdiction, but the delay of some months was fully explained, the intended grounds were arguable, and no prejudice to the respondent arose. Good cause having been shown, the extension was granted.

Outcome

Application allowed; time to lodge the notice and memorandum of appeal extended under section 28(6) of the Criminal Procedure Code Act.

Facts

The applicant, Sam Ssensalire, was convicted by the trial court in Criminal Case No. SUW/112 of 2025 on 27 April 2026. Under section 28(1) of the Criminal Procedure Code Act his notice of appeal fell due within fourteen days, that is by 11 May 2026, but he did not lodge it. He deposed that he was in prison and lacked the means to instruct counsel, and there was nothing on the record to show he had been informed of the appeal period or of the prison-lodgment procedure under section 30. His explanation was unchallenged. He indicated an intention to appeal on grounds that the trial court failed to evaluate the evidence, shifted the burden of proof onto him, and imposed a harsh and excessive sentence. The delay was measured in months. The respondent, through the Chief State Attorney, did not oppose the application and asserted no prejudice.

Issues

  1. Whether the applicant showed good cause under section 28(6) of the Criminal Procedure Code Act to justify an extension of time to lodge his appeal against conviction and sentence.

Orders

  • The application is allowed.
  • The time within which the applicant may lodge his notice of appeal and memorandum of appeal against the decision in Criminal Case No. SUW/112 of 2025 is extended under section 28(6) of the Criminal Procedure Code Act.
  • The applicant shall lodge his memorandum of appeal, together with his written submissions, within fourteen days from the date of this ruling.
  • The Registrar shall cause a copy of this ruling to be served on the applicant through the officer in charge of the prison in which he is held, and shall furnish the applicant and his counsel with a copy of the record of proceedings and the judgment of the trial court.
  • Upon compliance with order (c), the Registrar shall fix the appeal for hearing.
  • No order as to costs.

Rules and key headnotes

Criminal Procedure — Extension of Time to Appeal — Discretionary Nature of the Power under s.28(6)
The power to extend the time for lodging a criminal appeal under section 28(6) of the Criminal Procedure Code Act is discretionary and must be exercised judicially, upon good cause being shown, with reasons appearing on the record.
Criminal Procedure — Extension of Time — Meaning of Good Cause
Good cause for an extension of time must relate to the applicant's inability or failure to take the required step within time; a reason that merely shows the applicant is deserving of sympathy, or that the intended appeal is arguable, does not satisfy the statutory test.
Criminal Procedure — Extension of Time — Indigence and Incarceration of an Unrepresented Convict
Indigence and incarceration operating together upon an unrepresented convict who was not shown to have been informed of the appeal period or of the prison-lodgment procedure are capable of amounting to good cause for an extension of time to appeal.
Criminal Procedure — Extension of Time — Effect of the State's Non-Opposition
A concession by the State not to oppose an application for extension of time does not relieve the court of its duty to satisfy itself that good cause has been shown, because the jurisdiction conferred by section 28(6) is not conferred by consent.
Criminal Procedure — Extension of Time — Factors Governing the Exercise of Discretion
In exercising the discretion to extend time the court weighs together the length of the delay, the explanation offered, whether the intended appeal is frivolous or hopeless, and the prejudice an extension would occasion the respondent, no single factor being decisive.

Legislation cited (7)

Cases cited (7)

  • Rosette Kizito v Administrator General & Others (Supreme Court Civil Application No. 9 of 1986)
  • Sabiiti Kachope & 3 Others v Margaret Kamuje (Supreme Court Civil Application No. 31 of 1997)
  • [1998] UGSC 20
  • Pandya v R [1957] EA 336
  • Woolmington v Director of Public Prosecutions [1935] AC 462
  • Ssekitoleko v Uganda [1967] EA 531
  • Kiwalabye Bernard v Uganda (Supreme Court Criminal Appeal No. 143 of 2001)

Full judgment

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Sam Ssensalire v Uganda (Criminal Miscellaneous Application 236 of 2026) [2026] UGHCCRD 66 (10 August 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.