Uganda Trade Industrial Enterprise Ltd v Wanzima & 2 Ors (CIVIL APPEAL NO. 119 OF 2015)
Observed later treatment
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Holding
The High Court allowed the appeal, holding that where a court orders hearing notices to be issued, that order must be complied with through proper service evidenced by an affidavit of service under Order 5 rule 16 of the Civil Procedure Rules. The provisions governing service of summons apply equally to service of hearing notices. In the absence of proof of service, the exparte judgment was irregular and must be set aside.
Outcome
Exparte judgment set aside; matter remitted to Magistrate's Court for hearing on the merits
Facts
The Respondents filed Civil Suit No. 131/2011 against the Appellant. On 30 May 2012, when the suit was called for hearing, the Appellant and its counsel were absent. Counsel for the Respondents prayed that hearing notices be issued, undertaking to serve them herself. The court ordered: 'Adjourned to 4th July 2012. Let hearing notices issue.' On 4 July 2012, neither the Appellant nor its counsel appeared. Counsel for Respondents moved court to proceed exparte, which was granted, and judgment was entered in favour of the Respondents. The Appellant then filed Miscellaneous Application No. 046/2013 to set aside the exparte judgment on grounds that no hearing notices were served as ordered. The trial Magistrate dismissed the application, finding that although hearing notices were not served, the defendants were aware of the suit and should have attended. This appeal followed.
Issues
- Whether the learned trial Magistrate erred in dismissing the application to set aside the exparte judgment when no hearing notices were served on the appellant as ordered by the court.
- Whether the trial court properly evaluated the evidence and applied the law regarding service of hearing notices under Order 5 of the Civil Procedure Rules.
Orders
- Appeal allowed.
- Judgment and orders of the learned trial magistrate set aside.
- Appellant allowed to appear and defend the suit on its merits.
- Respondent to pay costs of the appeal and costs in the court below.
Rules and key headnotes
Legislation cited (4)
- Civil Procedure Rules O.5 r.10
- Civil Procedure Rules O.5 r.14
- Civil Procedure Rules O.5 r.16
- Civil Procedure Rules O.5 r.17
Cases cited (3)
- Pandya v R (1957) E.A 336
- Edison Kanyabware v Pastori Tumwebaze (Supreme Court Civil Appeal No. 6 of 2004)
- Kibuka Nelson and Another v Yusuf Zziwa (High Court Civil Suit No. 225 of 2008)
Cases citing this judgment (3)
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.