Wakilii

Walakira v Nakalanzi (Taxation Appeal No. 2 of 2019)

High Court · [2021] UGHCCD 259 · 2021 Appeal Allowed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Appeal from taxation decision following dismissal of civil suit for want of prosecution
Decision
Taxation award set aside; respondent and her advocates declared not entitled to costs

Observed later treatment

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Holding

Held that a bill of costs presented by law firms lacking proper notice of instructions and by an unqualified person not enrolled as an advocate is a nullity. Non-service of the taxation hearing notice and failure to hold a mandatory pre-taxation hearing are fatal irregularities denying a party the right to be heard. The taxation award was set aside and the respondent declared not entitled to costs.

Outcome

Taxation award set aside; respondent and her advocates declared not entitled to costs

Facts

The appellant instituted Civil Suit No. 281 of 2017 against the respondent at Rakai. The suit was dismissed for want of prosecution with costs to the respondent. The respondent filed a bill of costs which was initially struck out for non-compliance with drafting rules. A fresh bill of costs was filed by two law firms (Quest Advocates and T. Odeke & Co. Advocates) neither of which had filed a formal notice of change of advocates on the record. The bill of costs was not served on the appellant and was taxed ex parte without a pre-taxation hearing. The taxing master awarded costs. The law firm T. Odeke & Co. Advocates indicated that one Masawi Nicholas Wakubona, who was confirmed by the Chief Registrar not to be on the roll of advocates, had personal conduct of the suit and represented the respondent. The appellant appealed the taxation decision on multiple grounds including lack of locus, representation by an unqualified person, non-service, and excessive award.

Issues

  1. Whether the law firms representing the respondent at the taxation hearing had locus to file the bill of costs.
  2. Whether an unqualified person masquerading as an advocate was entitled to costs.
  3. What is the effect of non-service of bill of costs and failure to hold a pre-taxation hearing.
  4. Whether the award was unjustified or excessive.

Orders

  • Appeal allowed.
  • Taxation decision in Civil Suit No. 281 of 2017 set aside.
  • It is declared that neither the respondent nor her advocates are entitled to an award of costs.
  • Costs of the appeal to the appellant.

Rules and key headnotes

Taxation of Costs — Locus to Present Bill of Costs — Notice of Instructions
An advocate must have formal instructions from a litigant and must file a notice of instructions to acquire locus to represent that litigant and present a bill of costs on their behalf. In the absence of a notice of change of advocates or acceptance of instructions on the record, a law firm lacks locus to file and present a bill of costs.
Legal Profession — Unqualified Person Holding Out as Advocate — Effect on Costs
Under sections 64, 65, and 69 of the Advocates Act, it is an offence for an unqualified person not on the roll of advocates to hold themselves out as an advocate. Where such an offence is committed, there shall be no costs recoverable in the suit. A law firm that endorses and allows an unqualified person to represent a client is not entitled to costs arising from that suit.
Taxation of Costs — Service of Hearing Notice and Pre-Taxation Hearing — Mandatory Requirements
Non-service of the taxation hearing notice on the opposing party and failure to hold a pre-taxation hearing as required by sections 9, 10(2), and 13A of the Advocates (Remuneration and Taxation of Costs) Regulations are fatal irregularities that deny a party the constitutional right to be heard and render the taxation hearing and award a nullity.
Taxation Appeals — Standard of Review
A judge on taxation appeal should not interfere with the taxing officer's assessment of reasonable costs unless the award is manifestly excessive, exorbitant, or without legal or factual justification. However, procedural irregularities affecting the validity of the taxation process justify setting aside the award regardless of quantum.

Legislation cited (13)

Cases cited (5)

  • Bank of Uganda v Banco Arabe Espanol (Civil Application No. 23 of 1999)
  • Thomas James Arthur v Nyeri Electricity Undertaking [1961] EA 492
  • Musoke Mike and Mubiru Vincent v Kalumba James (Revision Cause No. 9 of 2019)
  • Edison Kanyabware v Pastori Tumwebaze (Civil Appeal No. 6 of 2004)
  • Auditor General v Ocip Moses and Others (Taxation Reference No. 89 of 2014)

Full judgment

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Walakira v Nakalanzi (Taxation Appeal No. 2 of 2019) [2021] UGHCCD 259 (29 April 2021)
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.