Wakilii

Solomon Serwagi Kasirye v Bernard Muhangi Bamwine and 8 Others (CIVIL SUIT NO. 645 OF 2018; MISC APPLIC NO. 2931 OF 2024)

High Court · [2026] UGHCLD 41 · 2026 Application Granted AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application under the Slip Rule to correct a clerical error in a judgment arising from Civil Suit No. 645 of 2018
Decision
Clerical error in judgment corrected under the Slip Rule; the plaintiff's entitlement to one third of the suit land now correctly recorded as 25 Hectares instead of 25 acres.

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The High Court has jurisdiction under the Slip Rule (section 99 of the Civil Procedure Act) to correct a clerical error in a judgment even where an appeal is pending, provided the correction gives effect to the manifest intention of the court and does not affect the substance of the orders. The words 'at any time' in section 99 permit amendment after an appeal has been lodged. The only impediment would be intervening circumstances rendering correction inexpedient or inequitable.

Outcome

Clerical error in judgment corrected under the Slip Rule; the plaintiff's entitlement to one third of the suit land now correctly recorded as 25 Hectares instead of 25 acres.

Facts

In Civil Suit No. 645 of 2018, judgment was delivered on 29 August 2023 awarding the plaintiff one third of land measuring 76 hectares. The judgment stated this as equivalent to '25 acres'. The plaintiff applied under the Slip Rule to correct this to '25 Hectares', arguing it was a clerical error. The 1st, 2nd, 3rd and 8th respondents opposed, contending that an appeal (Civil Appeal No. 68 of 2024) was pending and the Slip Rule could not be invoked after an appeal had been lodged. The respondents argued the correction would affect the merits of the appeal and that there had been inordinate delay (over two years).

Issues

  1. Whether the Court has jurisdiction to rectify its orders issued in Civil Suit No. 645 of 2018, out of which the respondents have a pending Civil Appeal No. 68 of 2024.

Orders

  • Application allowed.
  • Order No. 3 at page 32 of the Judgment in High Court Civil Suit No. 645 of 2018 amended to substitute '25 Hectares' for '25 acres'.
  • No order as to costs.

Rules and key headnotes

Civil Procedure — Slip Rule — Jurisdiction to Correct Clerical Errors After Appeal Lodged
The Slip Rule under section 99 of the Civil Procedure Act permits correction of clerical or mathematical mistakes in judgments at any time, including after an appeal has been lodged, provided the correction gives effect to the manifest intention of the court and does not alter the substance of the orders.
Civil Procedure — Slip Rule — Manifest Intention of the Court
The Slip Rule is intended for correction of an order which, if drawn up, did not express that which was decided by the court. The error or omission must be an error in expressing the manifest intention of the court.
Civil Procedure — Slip Rule — Impediments to Exercise of Jurisdiction
The only impediment to applying the Slip Rule is where there are intervening circumstances, such as the rights of third parties, that would render the proposed correction inexpedient or inequitable, or where it is unjust or prejudicial to make the correction.

Legislation cited (3)

Cases cited (3)

  • Quick Service v Thakrar [1958] EA 358
  • Vallabhdas Karsandas Raniga v Mansukhlal Jivraj and others [1965] EA 700
  • Moore v Buchanan [1967] 3 All ER 273

Full judgment

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

Solomon_Serwagi_Kasirye_v_Bernard_Muhangi_Bamwine_and_8_Others_(CIVIL_SUIT_NO._645_OF_2018;_MISC_APPLIC_NO._2931_OF_2024)_[2026]_UGHCLD_41_(23_February_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.