[1954] EACA 174

[1954] EACA 174

The court held that the restriction on the right of appeal under section 348 (2) of the Criminal Procedure Code applies only where the sentence consists of a fine not exceeding Sh. 100 and nothing more. In this case, the sentence included both a fine of Sh. 100 and an order for payment of costs of Sh. 8. The costs...

Source-derived case information.

Citation
[1954] EACA 174
Parties
Appellant: Maniben Jagjivan Chavde and another; Respondent: The City Council of Nairobi
Court
East African Court of Appeal
Jurisdiction
Uganda
Case Number
Criminal Appeal No. 81 of 1954
Procedural Posture
Criminal Appeal / Ruling on Preliminary Objection to Competence of Appeal
Outcome
Appeal is competent; right of appeal is not barred.
Judges
Bourke J
Legal Topics
Right of Appeal, Criminal Procedure Code Section 348 2, Penalty and Sentence, Costs in Criminal Cases
Source Language
en
Criminal Law Right of Appeal Criminal Procedure Code Section 348 2 Penalty and Sentence Costs in Criminal Cases

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Parties

Maniben Jagjivan Chavde and another

Appellant

The City Council of Nairobi

Respondent

Procedural Posture

Criminal Appeal / Ruling on Preliminary Objection to Competence of Appeal

  1. 1 Whether an order for costs in addition to a fine forms part of the sentence for the purpose of restricting the right of appeal under section 348 (2) of the Criminal Procedure Code.
  2. 2 Whether the appeal is barred where the fine imposed does not exceed Sh. 100 but costs are also ordered.

Ratio Decidendi

The court held that the restriction on the right of appeal under section 348 (2) of the Criminal Procedure Code applies only where the sentence consists of a fine not exceeding Sh. 100 and nothing more. In this case, the sentence included both a fine of Sh. 100 and an order for payment of costs of Sh. 8. The costs are considered a penalty forming part of the sentence. Therefore, the right of appeal is not barred, and the appeal is competent. The court analogized this situation to cases where an order for forfeiture forms part of the sentence, which also preserves the right of appeal even if the fine is Sh. 100 or less.

Court Disposition

Appeal is competent; right of appeal is not barred.

Orders

  • The preliminary objection to the competence of the appeal is overruled.
  • The appeal shall proceed on its merits.