Wakilii

Uganda Baati v Mubangizi Julius (Civil Application 7 of 2020)

Supreme Court · [2020] UGSC 25 · 2020 Application Granted AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application to strike out a notice of appeal for failure to take essential steps within the prescribed time
Decision
Notice of appeal struck out with costs to the applicant

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The Supreme Court struck out the respondent's notice of appeal. Having lodged the notice on 25 June 2015, the respondent took no further step to institute or prosecute the appeal — filing neither a memorandum nor record of appeal nor any request for the lower court record — contrary to rule 79. Adopting Lord Woolf's reasoning in Arbuthnot Latham Bank Ltd v Trafalgar Holdings Ltd against the warehousing of stale proceedings, the Court held that a party who delays inordinately and shows no intention to pursue an appeal cannot keep it pending indefinitely. The respondent having lost interest, the notice of appeal was struck out under rule 78 with costs to the applicant.

Outcome

Notice of appeal struck out with costs to the applicant

Facts

The respondent had been employed by the applicant as a roller man in its factory and suffered an industrial accident that reduced his capacity and led to his dismissal. He sued for wrongful dismissal, terminal benefits and general damages. After interlocutory disputes over the applicant's late defence and an ex-parte hearing order, the matter reached the Court of Appeal, which dismissed the respondent's appeal with costs. The respondent then lodged a notice of appeal in the Supreme Court on 25 June 2015. Thereafter he took no step to institute the appeal: he filed no memorandum or record of appeal and made no request for the lower court record. His advocates had lost contact with him and declined service of the strike-out application, and his whereabouts were unknown. The applicant applied to strike out the notice of appeal for non-compliance with the Rules.

Issues

  1. Whether the respondent's notice of appeal should be struck out where he failed to institute the appeal by filing a memorandum and record of appeal within the time prescribed by the Rules of the Supreme Court.

Orders

  • Application allowed.
  • Notice of Appeal lodged by the respondent on 25 June 2015 struck out.
  • Costs of the application awarded to the applicant.

Rules and key headnotes

Civil Procedure — Appeals — Striking Out Notice of Appeal — Failure to Take Essential Step Within Prescribed Time
A notice of appeal may be struck out under rule 78 of the Rules of the Supreme Court where the appellant fails to take an essential step in the proceedings, such as instituting the appeal by filing a memorandum and record of appeal within the time prescribed by rule 79.
Civil Procedure — Abuse of Process — Warehousing of Stale Proceedings — Duty to Prosecute Appeal
An appellant bears the duty to follow up and prosecute his appeal; inordinate delay without taking the necessary steps shows a loss of interest, and litigation may not be treated as an indefinite pastime nor proceedings warehoused until convenient to pursue.

Legislation cited (7)

  • Rules of the Supreme Court r.78
  • Rules of the Supreme Court r.79
  • Rules of the Supreme Court r.80
  • Rules of the Supreme Court r.72
  • Rules of the Supreme Court r.53(2)
  • Civil Procedure Rules O.9 r.10
  • Civil Procedure Rules O.9 r.11

Cases cited (1)

  • Arbuthnot Latham Bank Ltd v Trafalgar Holdings Ltd [1998] 1 WLR 1426

Full judgment

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Uganda Baati v Mubangizi Julius (Civil Application 7 of 2020) [2020] UGSC 25 (10 September 2020)
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.