Ssempijja v Attorney General and Others (Miscellaneous Cause 41 of 2023)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that a judicial review application filed before the decision being challenged has been made is premature and incompetent. The applicant filed the application on 20 November 2023 challenging the Minister's decision to convene a meeting to remove him as Speaker, but the actual removal decision was made on 29 November 2023. Judicial review concerns the decision-making process and cannot be invoked to challenge a process when no decision has yet been made. Application dismissed as not amenable to judicial review.
Outcome
Application dismissed as premature and not amenable to judicial review
Facts
The applicant was Speaker of Masaka City Council. On 24 October 2023, a petition was submitted seeking his removal from office for alleged breaches of the Standard Rules of Procedure for Local Government Councils in Uganda 2019. The Minister of Local Government scheduled a meeting for 29 November 2023 to consider the removal petition. On 20 November 2023, before the meeting took place, the applicant filed this judicial review application seeking to quash the Minister's decision to convene the meeting, prohibit the meeting from proceeding, and declare the Standard Rules ultra vires. The meeting proceeded as scheduled on 29 November 2023 and the applicant was removed from office. By the time of the ruling, the removal had already occurred.
Issues
- Whether the Application is competently before Court?
- Whether the Standard Rules of Procedure for Local Government Councils in Uganda of 2019 are illegal and/or ultra vires?
- Whether the process of removal of the Applicant from the office of the Speaker of Masaka City was illegal, procedurally improper and/or ultra vires?
- What remedies are available to the parties?
Orders
- Application dismissed.
- Costs awarded to the Respondents.
Rules and key headnotes
Legislation cited (18)
- Constitution of Uganda 1995 Article 42
- Constitution of Uganda 1995 Article 44
- Constitution of Uganda 1995 Article 185(2)
- Judicature Act s.33
- Judicature Act s.36
- Judicature Act s.38(2)
- Local Government Act Cap 243 s.175
- Interpretation Act Cap 2 s.15
- Interpretation Act Cap 2 s.16
- Interpretation Act Cap 2 s.17
- Interpretation Act Cap 2 s.18
- Interpretation Act Cap 2 s.19
- Interpretation Act Cap 2 s.20
- Judicature (Judicial Review) Rules 2009 Rule 6
- Judicature (Judicial Review) Rules 2009 Rule 8
- Judicature (Judicial Review) Rules 2009 Rule 5(1)
- Judicature (Judicial Review) (Amendment) Rules 2019 Rule 2(1A)
- Judicature (Judicial Review) Rules 2019 Rule 7A(1)(a)
Cases cited (1)
- Kadope v Uganda Revenue Authority (Consolidated Miscellaneous Cause No. 40 of 2019)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.