Wakilii

Uganda v Sserwadda & 6 Others (Miscellaneous Cause 14 of 2022)

High Court · [2022] UGHCICD 9 · 2022 Application Granted AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Ex parte application for witness protection orders arising from criminal proceedings in the International Crimes Division
Decision
Witness protection orders granted with conditions for delayed full disclosure before trial

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The court granted witness protection orders permitting redacted disclosure for fifteen witnesses and summary disclosure for two co-accused witnesses, with full disclosure to be made not later than fifteen days before trial commencement. The court held that the right to disclosure is not absolute and may be limited where there is an objectively justifiable risk to witness safety, provided the restrictions do not prejudice the accused's right to a fair trial.

Outcome

Witness protection orders granted with conditions for delayed full disclosure before trial

Facts

The respondents were jointly indicted on charges of terrorism, aiding and abetting terrorism, murder, and attempted murder, and were remanded at Kitalya Government Prison. During pre-trial proceedings, the prosecution sought protection orders for seventeen witnesses, alleging security threats and intimidation against them. The witnesses were factual witnesses whose evidence implicated the accused persons. The threats were said to emanate from the accused persons and their accomplices still at large. Two of the accused (A5 and A6) were Members of Parliament with resources and influence. The witnesses were permanent residents of Masaka where the prevailing security situation was described as delicate. The prosecution argued that a considerable time would elapse between disclosure and trial, and no protection measures were in place for the witnesses.

Issues

  1. Whether the prosecution should be granted witness protection orders including non-disclosure, delayed disclosure, redacted disclosure, and summary disclosure of witness identities prior to trial commencement.

Orders

  • Application allowed.
  • Redacted disclosure of fifteen witnesses (PE3-PE17) granted.
  • Summary disclosure of the evidence of two witnesses who are co-accused (PE1 and PE2) granted.
  • Redacted and summary disclosure to be done by 7th October 2022.
  • Full disclosure of the identities of the witnesses and evidence to be done not later than 15 days before commencement of the trial should the court confirm the charges.

Rules and key headnotes

Evidence — Disclosure — Witness Protection — Limitations on Right to Disclosure
The right to disclosure is not absolute and is subject to limitations established by evidence on grounds including protection of witnesses from intimidation, provided such limitations do not prejudice the accused's right to a fair trial.
Evidence — Witness Protection — Test for Restrictions on Disclosure
Restrictions on disclosure must be justified by showing: (1) the existence of an objectively justifiable risk to the safety of the person concerned; (2) the risk arises from disclosing the particular information to the defence; (3) the indefeasibility or insufficiency of less restrictive protective measures; (4) an assessment that the redactions are not prejudicial to or inconsistent with the rights of the accused and a fair trial; and (5) the obligation to periodically review the decision should circumstances change.
Criminal Procedure — Pre-Trial — Witness Protection Orders — Redacted and Summary Disclosure
Where there is an objectively justifiable risk to witness safety, the court may order redacted disclosure and summary disclosure of witness identities, provided full disclosure is made within a reasonable time before trial commencement to afford the accused adequate facilities to prepare their defence.

Legislation cited (7)

Cases cited (2)

  • Soon Yeon Kong Kim and Another v Attorney General (Constitutional Reference No. 6 of 2007)
  • The Prosecutor v Bosco Ntaganda (ICC-01/04-02/06)

Full judgment

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The original judgment as reported. Read the original PDF before relying on any passage.

Uganda v Sserwadda & 6 Others (Miscellaneous Cause 14 of 2022) [2022] UGHCICD 9 (3 October 2022)
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.