Wakilii

Uganda v Bukenya Richard (Cr.App. No.21 Of 2004) (Cr.App. No.21 of 2004)

High Court · [2005] UGHC 124 · 2005 Appeal Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Criminal appeal from Magistrate's Court acquittal dismissed on preliminary objection
Decision
Appeal struck out on preliminary objection for being incompetent

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

Held that a criminal appeal is incompetent where the memorandum of appeal is filed outside the fourteen-day statutory period prescribed by section 28(3) of the Criminal Procedure Code Act without leave of court. Further held that a ground of appeal stating only that the trial magistrate erred in law and fact in failing to properly evaluate evidence contains no particulars and is not a valid ground of appeal under section 28(4).

Outcome

Appeal struck out on preliminary objection for being incompetent

Facts

The respondent was acquitted by the trial magistrate on 29 October 2004. The appellant filed a notice of appeal on 8 November 2004 within the statutory fourteen-day period. The judgment copy was endorsed on 17 November 2004. The memorandum of appeal containing grounds was not filed until 14 February 2005, well outside the fourteen-day period prescribed by section 28(3) of the Criminal Procedure Code Act. The memorandum contained a single general ground alleging the magistrate erred in law and fact in failing to properly evaluate evidence.

Issues

  1. Whether the memorandum of appeal was filed out of time without leave of court and therefore incompetent.
  2. Whether the single general ground of appeal contained sufficient particulars of law or fact as required by statute.

Orders

  • Appeal dismissed.

Rules and key headnotes

Criminal Law & Procedure — Appeals — Time Limits — Filing of Memorandum of Appeal
Where an appellant files a notice of appeal within time but subsequently files the memorandum of appeal containing grounds outside the fourteen-day period prescribed by section 28(3) of the Criminal Procedure Code Act without obtaining leave of court, the appeal is incompetent and liable to be dismissed.
Civil Procedure — Grounds of Appeal — Particularity Requirement — Criminal Appeals
Under section 28(4) of the Criminal Procedure Code Act, where an appellant is represented by an advocate or the appeal is preferred by the Director of Public Prosecutions, the grounds of appeal must include particulars of the matters of law or fact in which the lower court is alleged to have erred. A general ground alleging only that the trial magistrate erred in law and fact in failing to properly evaluate evidence, without specifying the particular errors, bears no particulars and is not a valid ground of appeal.

Legislation cited (3)

Full judgment

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Uganda v Bukenya Richard (Cr.App. No.21 Of 2004) (Cr.App. No.21 of 2004) [2005] UGHC 124 (27 July 2005)
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.