[1995] UGHC 55

[1995] UGHC 55

The trial magistrate's sentence was illegal because it exceeded the statutory maximum fine and improperly allowed the accused to choose between imprisonment and a fine. Section 113(1)(a) of the TRSA 1970 prescribes a maximum fine of 5,000 shillings or imprisonment not exceeding two years, or both, at the court's...

Source-derived case information.

Citation
[1995] UGHC 55
Parties
Applicant: Uganda; Respondent: Ben Selcatulca
Court
High Court of Uganda
Jurisdiction
Uganda
Case Number
Criminal Revision 10 of 1995
Procedural Posture
Criminal Revision / Order on Revision
Outcome
sentence set aside and substituted; excess fine ordered refunded
Judges
GM OKELLO, J
Legal Topics
Sentencing Illegality, Magistrate Powers, Revision of Sentence
Source Language
en
Criminal Law Sentencing Illegality Magistrate Powers Revision of Sentence

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Parties

Uganda

Applicant

Ben Selcatulca

Respondent

Procedural Posture

Criminal Revision / Order on Revision

  1. 1 Whether the sentence imposed by the trial magistrate was in accordance with section 113(1)(a) of the TRSA 1970.
  2. 2 Whether the accused could be given the option to choose between imprisonment and a fine exceeding the statutory maximum.

Ratio Decidendi

The trial magistrate's sentence was illegal because it exceeded the statutory maximum fine and improperly allowed the accused to choose between imprisonment and a fine. Section 113(1)(a) of the TRSA 1970 prescribes a maximum fine of 5,000 shillings or imprisonment not exceeding two years, or both, at the court's discretion. The magistrate imposed a fine of 75,000 shillings or six months imprisonment at the accused's option, which is not permitted by law. The High Court set aside the illegal sentence and substituted it with a lawful sentence: a fine of 5,000 shillings or, in default, one month imprisonment. The excess fine paid by the accused was ordered to be refunded.

Court Disposition

sentence set aside and substituted; excess fine ordered refunded

Orders

  • The sentence imposed by the trial magistrate is set aside.
  • The accused is sentenced to a fine of 5,000 shillings or, in default, to serve one month imprisonment.