THE REPUBLIC OF UGANDA

IN THE HIGH COURT OF UGANDA AT KAMPALA

CIVIL DIVISION

MISCELLANEOUS CAUSE NO. …….......….. OF 2022

(ARISING OUT OF MISCELLANEOUS CAUSE NO. …..OF ….)

………………….. ……………………………........…………………..…………... APPLICANT

VERSUS

ATTORNEY GENERAL….....................................................……………………RESPONDENT

NOTICE OF MOTION
(Brought under Art 126 (2)(e) of the Constitution, O. 52 r. 1, 2,3 & 4 of the CPR,
Section 19 (1) & (2) of the Government Proceedings Act, Rule 14 (1),(2) & (3) of the
Government Proceedings (Civil Procedure) Rules, Sect.33 of the Judicature Act, Section
98 of the CPA)

TAKE NOTICE that this Honorable Court shall be moved on the ……… day of
…………………………..2022 at …… O’clock in the forenoon/afternoon or soon thereafter as
Counsel for the applicant can be heard on the application for orders that:

1. A Certificate of order be issued against government.

2. Costs of the Application be provided for.

TAKE FURTHER NOTICE that this application is supported by the grounds set forth in
the affidavit of Counsel of the applicant ………, the applicant herein which shall be read
and relied upon at the hearing but briefly the grounds thereof that;

1. The applicant instituted Misc. Cause No. ….. against the respondent for
violation of her rights.

2. The High Court delivered a ruling in the applicant’s favour on the 7 th

February, 2020 where it was decreed that the applicant’s freedom from
torture, inhumane and degrading treatment and right to liberty was violated.
 3. That, the court ordered the applicant to be paid damages of 200,000,000/=
(two hundred millions) and costs.

4. The applicant filed her bill of costs which was taxed and allowed at Ug shs.
7,260,000/= (Seven Millions two hundred sixty thousand shillings).

5. The respondent was served with the ruling, order and certificate of taxation,
however, to-date the applicant has not been paid.

6. This honourable court has jurisdiction to issue a certificate of order against

the respondent.

7. It is only fair and just that this application be granted.

Dated at Kampala this …………… day of ……..……………………..…… 2022.

……………..……………………….
COUNSEL FOR THEAPPLICANT

GIVEN under my hand and seal of this Honorable Court this ……..... day of
…………………………….. 2022.

……………………………………
Deputy Registrar

DRAWN AND FILED BY:

M/s Firm A & Co. Advocates
Plot …..,
P.O. Box …..., Kampala
 THE REPUBLIC OF UGANDA

IN THE HIGH COURT OF UGANDA AT KAMPALA

CIVIL DIVISION

MISCELLANEOUS CAUSE NO. …….......….. OF 2022

(ARISING OUT OF MISCELLANEOUS CAUSE NO. …. OF ….)

………………………….. ……………………………........…………………..…………... APPLICANT

VERSUS

ATTORNEY GENERAL….....................................................……………………RESPONDENT

AFFIDAVIT IN SUPPORT OF NOTICE OF MOTION

I, …….. OF C/O M/S ………. & Co. Advocates, Plot ….Kampala Road, 15, P.O Box ………
Kampala, Tel. No. ……, do solemnly swear that;

1. I am a female adult of sound mind and the applicant herein.

2. I instructed my lawyers c/o M/s ……. to institute a suit for violation of my right of
personal liberty, freedom from torture, cruel and inhumane treatment inter-alia.
3. My lawyers instituted MISCELLANEOUS CAUSE NO.295 OF 2018 against the
Attorney General for violation of the said rights.
4. On the 7/2/2020, court issued an order in my favour wherein it was decreed that my
freedom from torture, inhumane and degrading treatment and right to liberty was
violated.(See a copy of the Ruling and order annexed and marked “A” & “B”
respectively).
5. That, the Court ordered that I be paid Ug.shs. 200,000,000/= (Two hundred
millions) as compensatory and punitive damages.
6. Court also ordered that I be paid costs.
7. My counsel filed a Bill of Costs which was taxed and allowed at 7,260,000/= (Seven
Millions two hundred sixty thousand shillings).(See a copy of the certificate of
taxation attached and marked “C”).
8. I have been informed by my lawyers which information I verily believe to be true
that he wrote a letter to the respondent demanding for payment of the said money.
See copy of the letter attached and marked “D”.
9. However, to-date, I have not been paid.
10. That, due to torture, inhumane and degrading treatment subjected onto me, I
sustained grave injuries on my legs which have led to the rotting of the same. See
medical evidence attached and marked “Group E”.
11. My legs need urgent medical attention/treatment but for the delay of payment, I
cannot access the necessary treatment due to lack of money.
12. I have been advised by my lawyers that to-date, the respondent has not appealed
the decision of court.
13. That, it is in the interest of time and a lifesaving matter that a certificate of order is
issued against the government.
14. I swear this affidavit in support of an application for a certificate of order and
whatever I have stated herein is true and correct to the best of my knowledge and
belief save for information whose source has been disclosed.

DATED at Kampala this ………………. Day of …………………………………… 2022.

By the said ………..

…………………………………………….
DEPONENT

BEFORE ME;

…………………………………………………..
COMMISSIONER FOR OATHS

DRAWN AND FILED BY:

M/s Firm A & Co. Advocates
Plot …..,
P.O. Box …..., Kampala