[1951] EACA 138

[1951] EACA 138

The applicant had no right of appeal against the Magistrate's order of forfeiture following acquittal. The alternative remedy of revision is discretionary and does not confer a right to be heard, thus cannot be considered a lesser remedy in the sense of a legal right to judicial intervention. Since the Magistrate...

Source-derived case information.

Citation
[1951] EACA 138
Parties
Applicant: R. S. Varma; Respondent: Crown
Court
East African Court of Appeal
Jurisdiction
Uganda
Case Number
Miscellaneous Criminal Case No. 7 of 1951
Procedural Posture
Miscellaneous Criminal Application / Judgment
Outcome
order nisi made absolute; order of forfeiture set aside; no costs awarded
Judges
Bourke J, Hearne CJ
Legal Topics
Certiorari, Jurisdiction of Magistrate, Forfeiture of Licences, Remedies in Criminal Procedure
Source Language
en
Criminal Law Administrative Law Certiorari Jurisdiction of Magistrate Forfeiture of Licences Remedies in Criminal Procedure

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Summary, issues, holding and outcome

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Parties

R. S. Varma

Applicant

Crown

Respondent

Procedural Posture

Miscellaneous Criminal Application / Judgment

  1. 1 Whether the Magistrate had jurisdiction to order forfeiture of licences after acquittal.
  2. 2 Whether certiorari is available where no right of appeal exists.
  3. 3 Whether revision is a lesser remedy than certiorari.

Ratio Decidendi

The applicant had no right of appeal against the Magistrate's order of forfeiture following acquittal. The alternative remedy of revision is discretionary and does not confer a right to be heard, thus cannot be considered a lesser remedy in the sense of a legal right to judicial intervention. Since the Magistrate acted without jurisdiction and no adequate alternative remedy existed, certiorari is the appropriate remedy to quash the unlawful order.

Court Disposition

order nisi made absolute; order of forfeiture set aside; no costs awarded

Orders

  • The order nisi is made absolute.
  • The order of the Magistrate forfeiting the applicant's licences is set aside.