Wakilii

Waako Robina v Stanbic Bank Uganda (Miscellaneous Application No. 470 of 2025)

High Court · [2026] UGHC 73 · 2026 Application Granted AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application arising from Letters of Administration for rectification of name discrepancy
Decision
Application granted; applicant confirmed as lawful administrator with name discrepancy resolved

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The High Court granted a declaration that Waako Robina and Robina E. Waako refer to one and the same person. Applying the doctrine of misnomer and the reasonable reader's test, the court found that the variation between the full name on the National ID and the abbreviated form on the Letters of Administration was a classic misnomer, with consistent core names (Waako and Robina) and only the abbreviation of the middle name Elizabeth to E. The court directed the respondent bank to recognize the applicant as lawful administrator regardless of the name variation.

Outcome

Application granted; applicant confirmed as lawful administrator with name discrepancy resolved

Facts

The applicant is the widow of the late Waako Nabeta Neeri Hosai. On 23 June 2015, the High Court granted her Letters of Administration in Administration Cause No. 308 of 2015. A discrepancy arose between her name as it appears on the Letters of Administration (Robina E. Waako) and her National Identification Card (Waako Robina). This discrepancy prevented her from accessing the deceased's pension benefits from Stanbic Bank Uganda. The applicant sought a declaration that both names refer to the same person to enable proper administration of the estate. The respondent did not contest the application.

Issues

  1. Whether the name discrepancy between 'Waako Robina' on the National ID Card and 'Robina E. Waako' on the Letters of Administration constitutes a misnomer referring to the same person.
  2. Whether the court should grant a declaration confirming that both names refer to one and the same person to enable the applicant to administer the estate.

Orders

  • Waako Robina and Robina E. Waako refer to one and the same person, the Applicant.
  • The Applicant's names as appearing on her National Identity Card and the Letters of Administration in HCT-03-CV-AC-308-2015 refer to one and the same person.
  • The Respondent is directed to recognize the Applicant as the lawful Administrator of the estate of the late Waako Nabeta Neeri Hosai regardless of the aforementioned name variations.
  • The costs of this application shall be borne by the estate.

Rules and key headnotes

Letters of Administration — Misnomer — Name Discrepancy Between Grant and National ID
Where there is a discrepancy between the name on Letters of Administration and the administrator's National ID Card, the court may grant a declaration that both names refer to the same person if the variation constitutes a misnomer under the reasonable reader's test, particularly where core names are consistent and only a middle name is abbreviated.
Misnomer — Reasonable Reader's Test — Application
The reasonable reader's test for misnomer asks whether a reasonable person receiving the document would say 'Of course it must mean me, but they have got my name wrong.' A classic misnomer includes the use of a full middle name rather than merely a middle initial, or vice versa.
Inherent Jurisdiction — Section 98 Civil Procedure Act — Rectification of Name Discrepancy
Under Section 98 of the Civil Procedure Act, the court has inherent power to make orders necessary for the ends of justice, including rectifying name discrepancies that would otherwise create insurmountable hurdles in the administration of an estate.
Evidence — Uncontroverted Affidavit — Presumption of Truth
Where facts are deposed in an affidavit and remain unchallenged or denied by the respondent, they are presumed to be true under Sections 101, 102, and 103 of the Evidence Act.

Legislation cited (6)

Cases cited (5)

  • Samwiri Massa v Rose Achen [1978] HCB 297
  • Makerere University v St Mark Education Institute Ltd & Others (1994) KALR 26
  • Kaggwa Micheal v Olal Mark & 6 Others (Civil Appeal No. 10 of 2017)
  • Sabric International Limited v Attorney General (Supreme Court Civil Appeal No. 30 of 2020)
  • Davies v Elsby Brothers Limited [1960] 3 All ER

Full judgment

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

Waako Robina v Stanbic Bank Uganda (Miscellaneous Application No. 470 of 2025) [2026] UGHC 73 (13 February 2026)
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.