Wakilii

Waiswa Jamada & 2 Others v Uganda (Criminal Application No. 0022 of 2019)

Court of Appeal · [2019] UGCA 2024 · 2019 Application Granted AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application to reinstate a criminal appeal dismissed for non-appearance
Decision
Application allowed; dismissed criminal appeal reinstated for hearing on its merits

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The Court of Appeal considered an application under rule 73(7) of the Court of Appeal Rules to reinstate a criminal appeal dismissed for the applicants' non-appearance. The Court held that 'sufficient cause' includes ignorance of procedure by an unrepresented litigant. The applicants, then unrepresented, had provided an imprecise address on their notice of appeal, resulting in non-service of the hearing notice; this ignorance amounted to sufficient cause. The Court also affirmed that on such applications it does not concern itself with the merits of the appeal. The application was allowed and the appeal reinstated for hearing on its merits, with no order as to costs.

Outcome

Application allowed; dismissed criminal appeal reinstated for hearing on its merits

Facts

The three applicants were convicted by the Chief Magistrate's Court of forcible entry contrary to section 77 of the Penal Code Act. On appeal, the High Court quashed that conviction, substituted a conviction for criminal trespass under section 302, and imposed sentences which the applicants have since fully served. Dissatisfied, they lodged a notice of appeal to the Court of Appeal (Criminal Appeal No. 0817 of 2014), which was dismissed for their non-appearance. In their notice of appeal the applicants, then unrepresented, had provided an imprecise address, and as a result the court process servers could not serve them with the hearing notice. They subsequently filed the present application, together with a memorandum of appeal and record of proceedings, seeking reinstatement. An earlier panel had adjourned the matter to allow filing of the record and memorandum of appeal.

Issues

  1. Whether the applicants were prevented by sufficient cause from appearing when their appeal was called for hearing, so as to justify reinstatement of the dismissed appeal under rule 73(7).

Orders

  • Criminal Appeal No. 0817 of 2014 reinstated and to be heard on its merits.
  • The applicants to take steps to file all documents relevant to the prosecution of their appeal within 14 days from the date of this ruling.
  • Application allowed with no order as to costs.

Rules and key headnotes

Reinstatement of Dismissed Appeal — Rule 73(7) — Meaning of 'Sufficient Cause'
A court may restore an appeal dismissed for non-appearance under rule 73(7) of the Court of Appeal Rules where it is satisfied that the appellant was prevented by sufficient cause from appearing when the appeal was called for hearing; the discretion to restore must be exercised judiciously.
Sufficient Cause — Ignorance of Procedure by Unrepresented Litigant
Ignorance of procedure or the law by an unrepresented litigant may constitute sufficient cause; where an unrepresented applicant provided an imprecise address leading to non-service of a hearing notice, that ignorance amounts to sufficient cause for reinstating a dismissed appeal.
Reinstatement Applications — Merits of Appeal Not Considered
In determining an application to reinstate a dismissed appeal or set aside an ex parte judgment, the court is not concerned with the merits of the underlying appeal.

Legislation cited (4)

Cases cited (5)

  • Nicholas Roussos v Ghulam Hussein Habib Virani (Civil Appeal No. 9 of 1993)
  • Shabin Din v. Ram Parkash Anand (1955) 22 EACA 48
  • Zirabamuzaale v. Correct (1962) E.A. 694
  • Patel v. Star Mineral Water and Ice Factory (1961) E.A. 454
  • Mitha v. Ladak (1960) E.A. 1054

Full judgment

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

Waiswa Jamada & 2 Others v Uganda (Criminal Application No. 0022 of 2019) [2019] UGCA 2024 (21 November 2019)
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.