Uganda Revenue Authority v Wilberforce Dega (Miscellaneous Application 54 of 2025)
Observed later treatment
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Holding
The High Court granted an interim stay of execution of the judgment in Civil Suit No. 28 of 2023 pending determination of the substantive application for stay. The Court held that despite the Notice of Appeal being filed out of time, the applicant satisfied the essential requirements: a substantive application for stay was pending, and there was imminent threat of execution evidenced by a taxation hearing notice. The Court exercised inherent discretion to preserve the status quo where there was clear intention to appeal and risk of substantial loss.
Outcome
Interim stay of execution granted pending determination of substantive application
Facts
The applicant Uganda Revenue Authority filed this application seeking an interim stay of execution of the judgment in High Court Civil Suit No. 28 of 2023 pending determination of the substantive application for stay (Miscellaneous Application No. 51 of 2025). Judgment in the underlying suit was delivered on 3rd October 2024. The applicant filed a Notice of Appeal on 21st October 2024, beyond the statutory 14-day time limit. The applicant filed the substantive application for stay (MA No. 51 of 2025) which was pending hearing. The respondent had taken steps towards execution by issuing a Taxation Hearing Notice fixed for 12th March 2025. The respondent opposed the application on grounds that the appeal had no merit and the Notice of Appeal was filed out of time.
Issues
- Whether the applicant satisfied the conditions for an interim stay of execution pending determination of the substantive application for stay.
Orders
- An order for an Interim Stay of Execution of the Judgement in High Court Civil Suit No. 28 of 2023 is hereby granted pending the hearing and final determination of High Court Miscellaneous Application No. 51 of 2025.
- Costs shall be in the cause.
Rules and key headnotes
Legislation cited (7)
- Civil Procedure Act s.98
- Judicature Act s.33
- Civil Procedure Rules O.52 r.2
- Civil Procedure Rules O.52 r.3
- Judicature (Court of Appeal Rules) Directions r.42(2)
- Civil Procedure Rules O.43 r.4(3)
- Judicature (Court of Appeal Rules) Directions S.I. 13-10 r.4(2)
Cases cited (7)
- Hwang Sung Industries Limited v Tajdin Hussein & Others (SC Civil Application No. 19 of 2008)
- Yakobo Senkungu and others v Cerencio Mukasa (SC Civil Application No. 5 of 2013)
- Lawrence Musiitwa Kyazze v Eunice Businge (SC Civil Application No. 18 of 1990)
- Zubeda Muhammad v Laila Kaka (SC Ref. No. 07 of 2016)
- Junaco (T) Limited & 2 Ors v DFCU Bank Limited (HC MA No. 0027 of 2023)
- Airtel Uganda Limited v Garfield Spence a.k.a Konshens & Others (Miscellaneous Application No. 0560 of 2024)
- Guiliano Gariggio v Claudio Casadio (SCCA No. 3 of 2013)
Cases citing this judgment (1)
How later Ugandan judgments in the Wakilii corpus have cited this case. Treatment labels come from Sequitur — Uganda’s citator — each backed by a verbatim span from the citing judgment, and are not an assertion that this case is, or is not, good law.
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.