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Z aoe va] RECEIVE 2 AT REQEPTIC BD DATE... Asingwir P & Part @¥fe REPUBLIC OF UGANDA OF 2019 1. THE WOMEN’S PROBONO INITIATIVE (WPD) 2. GIMBO ZUBEDA 3. KAKAI ANNET. ssseesees APPLICANTS VERSUS 1, RENEE BACH 2. SERVING HIS CHILDREN (SHC) RESPONDENTS NOTICE OF MOTION (Brought under Article 50(2) of the Constitution of the Republic of Uganda, 1995. rule 3 of the Judicature (Fundamental Rights and Freedoms) (Enforcement Procedure) Rules of 2008.) th TAKE NOTICE that this Honourable court will be moved on the .j.dday of raacch20...\2\...atUscQ.an6’clock in the fore afternoon or soon thereafter as Counsel for the Applicants can be heard on behalf of the Applicants for: DECLARATIONS 1. A declaration that the Respondents violated the right of the 2“ and 3" Applicants’ children’s right to proper medical care when they operated and purported 1o treat them in an illegal ‘medical facility’ in Masese 1, Jinja TY REGISTRAR GH COURT JIA ee eee 5-2 (eM WstrghWithout a license contrary to Articles 34(3), 8A, 45 and Objective ACG ADS S DEPOSITS. FOR DEPUTY REGISTRAR HIGH COURT JINJA. PEEEEEEEEE | EFI EGS and XIV(b) of the National Objectives and Directive Principles of State Policy of the Constitution of the Republic of Uganda, 1995 A declaration that the Respondents violated the 2™ and 3“ Applicants’ right to health when they operated an illegal medical facility” in Masese 1, Jinja without a license and recruiting people to tout vulnerable children from communities to their facility contrary to Articles 8A, 45 and Objective XX and XIV (b) of the National Objectives and Directive Principles of State Policy of the Constitution of the Republic of Uganda, 1995 A declaration that the 1“ and 2” Respondents violated the 2“ and 3 Applicants children’s right to life when they operated a ‘medical facility without a license leading to the death of hundreds of children ineluding those of the 2 and 3" Applicants contrary to Article 22(1) of the Constitution of the Republic of Uganda, 1995, 4. A declaration that the 1 and 2™ Respondents violated the 2” and 3“ Applicants right to dignity and freedom from cruel, inhuman and degrading treatment and psychological torture to contrary to Article 24 and 44 (a) of the Constitution of the Republie of Uganda, 1995 A declaration that the 1" Respondent's act of treating Ugandan children without proper medical training and certification is a violation of the right to equality and freedom from discrimination on the ground of race and social status contrary to Article 2 ¢ Constitution of the Republic of Uganda, 1995 ORDERS 1. An order that all ope S 1" and 2" Respondents cease with immediate effect from the ement of this Honourable Court. 2. An order for an award of general damages to the 2™ and 3" Applicants for violation of their human rights. TAKE NOTICE that this application is supported by grounds set out in the affidavit A SI JOLLEY, of GIMBO ZUBEDA, KAKAI ANNET, KYEBANAKC OLANA JOYCE, CHARLES OLWENY, JACQUELINE. GRACE KRAMEICH, OS DANIELLE -ACTTO,-ASHLEY-LAVERTY and KAYAGA BEATRICE which shall ies and relied upon at the hearing but briefly are: ) gu ee eat ara f a coer") ©°"1. The Respondents run and operate the Second Respondent organisation in Masese. Jinja District. 2. That the said Respondents provide medical treatment to children from the areas of Masese landing site, Buvuma, Kigandaalo, Namutumba, Mayuge District stretching into far Eastern Uganda. That the First and Second Respondent are not licensed as a medical practitioner and medical facility respectively but have unlawfully practiced medicine and offered ‘medical services” to unsuspecting vulnerable children. 4. That the 2" Respondent was closed by the Jinja District Health Services Office in the year 2015 and ordered to refer all children under its care to available government health facilities but still continues to admit ill children to its premises. 3. That the 2" and 3" Applicants’ children were recruited into the 2"! Respondents facility, treated by the Respondents and the 1“ Applicants Child died in their facility