Submission of The Amici Curiae For The Uganda Presidential Petition of 2016
Submission of The Amici Curiae For The Uganda Presidential Petition of 2016
URT OF UGANDA
EIVED
*
C:IVIL APPLICATION NO. 2 OF 2016
ARISING FROM
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SLVIA.TA:MALE
ASSOC. PE.()F. CHRISTOPHER MBAZIRA
DR. RONALD NALUW AIRO
l)R. ROSENAKAYI
DR. BUSINGYE KABUMBA
MR. DANIEL RUHWEZA
DR. KAKUNGULU MAYAMBALA
MR. DANIEL NGABIRANO
]
]
]
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]:::::::::::::::::AMICI
]
]
]
]
]:::::::::: PETITIONER
AND
1. YOWERIKAGUTAMUSEVENI
2. ELECTORAL COMMISSION
3. THE ATTORNEY GENERAL
] :::::::RESPONDENTS
]
(Under Articles 1, 3(4), 17, 54, 104(5), 126(1), 127 and 128(3) of the
Constitution of the Republic of Uganda, 1995 (as Amended), Objective XXIX
of the Constitution, Section 59(3) of the Presidential Election Act No.16/2005,
Rule 2(2) of ;the Judicature (Supreme Court Rules) Directions, S.I. 13-11,
Regulation 15 of the Presidential Elections (Election Petitions) Rules, S.I. No.
13 of 2001, Sections 14, 33 & 39(2) of the Judicature Act, Cap 13, Section 98
of the Civil Procedure Act, Cap 71, Order 52 of the Civil Procedure Rules,
S.I. 71-1 And/or any other enabling Laws, Rules and Regulations).
Page 2 of 33
TABLE OF CONTENTS
I.
INTRODUCTION ..................................................................................................................... 4
II.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
Historical context of inadequate electoral law and practice: An Incomplete Transition ................ 19
V.
B.
Page 3 of 33
I.
INTRODUCTION
,-
1. If it may please the Court, this is the final version of the Amici Curie
submissions in these proceedings.
2. A core value of the School of Law at Makerere University is to serve tl
community and to stand up for the rights of citizens with integrity ar
excellence. In this respect, we have come together as scholars ar
researchers of Constitutional Law, Human Rights and Democrat
Governance and in execution of our civic responsibility as citizens ~
Uganda. This Brief is designed to assist the Court in its due inquiry
respect of the matter before it so as to enable it to come to a just decision
this matter.
In light of the ruling of this Honourable Court in Prof J. Oloka-Onyango ,
8 Ors. (Amici) In the Matter of Amama Mbabazi v. Yoweri K. Museveni &
Ors., 1 the following issues are addressed in these submissions:
a. Some New Reflections on the concept of Amicus Curiae in Uganda;
b. Electoral Law Reform;
c. Institutional Changes, and
d. The question of enforcement.
3. Your Amici take note of your directions to make practical proposals and 1
offer possible remedies beyond declarations which can be pursued by th
Honourable Court. In particular, we mainly focus on the issue <
enforcement, which is found in section V of this brief, and which we sub m
to be your Amici's major contribution to the jurisprudence in this are
Nevertheless, we have also provided some further input on the matte:
traversed in sections II to IV of the brief. For ease of reference, all matte:
which are newly introduced in this brief are outlined in bold.
4. In making the proposals, your Amici are mindful of the contributio
they bring to this Petition as stated in Civil Application No. 2 of 2016:
Supreme Court Civil Application No.2 of2016, arising from Presidential Petition No. I of2016.
Page 4 of 33
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are,,present~d
a) The obligation of state agencies and organs under Article 128(3) to act
upon the observations on legislative and other electoral reforms
contained in Presidential Petition No.1 of 2001 and Presidential
Petition No. 1 of 2006;
b)The impact of the
lack of action on the Supreme Court
recommendations in Presidential Petition No. 1 of 2001 and
Presidential Petition No. 1 of 2006 and its effect on the 2016
Presidential election under Article 1(4) of the Constitution, and
c) The nature and type of remedial measures this Court can take to cure
the effect of the said lack of action.
II. SOME NEW REFLECTIONS ON THE CONCEPT OF AMICUS CURIAE
IN UGANDA
5. The ruling of this Honourable Court in the case of 0/oka-Onyango & 8
Ors., has provided a new and fairly comprehensive template for dealing
with the issue of amicus curiae briefs in general and in relation to their
place in presidential election petitions in particular. It gives effective
translation to the provisions of Article 126(1) on the exercise of judicial
power. , It is esp~cially important with respect to the clarification it
provides on matters such as bias, public interest and the expertise of the
Amici.
'
Ill.
implementation of the suggested reforms will greatly reduce on electionrelated disputes. In pursuance of this goal, the emphasis in this brief has
been placed on reforms directed towards improving the independence and
credibility of the Electoral Commission (EC) and matters related thereto.
Page 7 of 33
2
3
Central London Property T;11st Ltd v. High Trees House Ltd. [1947] KB 130.
Besigye v. Museveni I, Judgment of Odoki CJ, p41.
Besigye v. Museveni I, Judgment ofMulenga JSC, p821.
Page 8 of 33
As above.
As above.
Page 9 of 33
See., Electoral Commis~ion, Revised Milestonesfor the 2015-2016 General Elections Road Map, dated 2"d
October, 2015, Ref. ADMIN/72/0 I, Available at,
http://www .ec.or.ug/si tes/default/files/press/Roadmap%20for%2020 15-20 16%20General%20Elections.pdf,
accessed March 16th March, 2016.
10
Besigye v. Museveni I, Judgment ofTsekooko JSC, pp513-514.
11
Besigye v. Museveni I, Judgment ofTsekooko JSC, p514. See, to the same effect, Judgment ofKarokora JSC, at
661.
12
Besigye v. Museveni I, Judgment of Oder JSC, p206.
Page 10 of33
9
14
'good time." 23 A similar call was made by Katureebe JSC (as he then was) in
Besigye v. Museveni II, wherein he noted the importance of enacting all
requisite laws be in a timely manner so as to enable the Electoral
'Commission to effectively perform its role. 24
FJ:l. ''IJI'h~. AmicliJii'o~e',>;;that(:wUh .re~pect to the... Just-concluded electoral
cy.CJe, !amend111erits 4o r1the/ :primacy l{igishitiori-.-.. th.e Electoral
Commission
Act artd;the' Presidenth1l Electiolis Act-were enacted as
.
late as November, 2015. This was well into the campaign period of the
cycle and implies that aspects of the law were only partially
implemented. It is our considered suggestion that any reforms which
are to be made to election-related laws be undertaken within two (2)
years of the establishment of a new parliament in order to do away with
the practice of last-minute, hastily-enacted legislation on elections. Such
early enactment of the necessary laws will mean that any changes which
need to be made later in the electoral cycle will not be of a fundamental
nature. It would also match with the spirit of various provisions of the
electoral laws, including Section 3(1) of the Presidential Elections Act of
2005 (Aspirant Consultations).
.
I,
25
26
Page 13 of33
Assistants. 27 In his view therefore, law reform was crucial for gaps in the
law to be addressed? 8
Similarly, in Bestgye v. Museveni II, Odoki CJ noted the "partisan and
partial conduct of some electoral officials like presiding offers and other
polling; ,officials. who:engaged ,in ,el~cton:tl ,malpractices :lik.errtultiple voting"
and cal!led upon,, .the 1'}3C ::to. ''provide suitable training <,iS well as effective
supe1wision of such:,offiCia1s.'~ 29
FL The Amici are of the strong view that the ailments isolated above
relate to a larger problem than the lack of training and effective
supervision. It is our considered view that there is a need to introduce a
transparent, competitive and merit-based process to the recruitment,
vetting and ap,pOintment of all election officials. That need is manifest
right from the l~vel of the chairperson and the commissioners down to
All officers of the
the presiding officers and polling officials.
Commission need not only to be impartial, but must be seen to be
impartial. They must desist from partisan commentary in favour or
against any of the presidential candidates. They must be seen to be
consulting and cooperating with all sides in the electoral process, rather
than appearing to be taking orders from any one official and/or
institution whether of the State or of the official political opposition.
F2. The Amici emphasize that the officials of the Electoral Commission
are not traditional civil servants in the employ of the government. The
chairperson and commissioners are members of a constitutional body
which is a special kind of institution created by the 1995 Constitution,
standing alongside the Uganda Human Rights Commission, especially in
terms of its independence (Article 62). While the tenure of the
chairperson ~.nd commissioners is not as secure as that of judges of the
courts of judicature, they can only be removed for just cause under
Article 60(8),\on the advice of a Tribunal duly constituted under Article
60(9). This is a unique kind of independence which should be duly
27
As above.
As above.
29
Besigye v. Museveni ll, Judgment of Odoki CJ, p 152. See also, Besigye v Museveni II, Judgment of Kanyeihamba
JSC, at p324, citing the partisan nature of, among others, national electoral agents, 'to the extent of showing bias
and, in some instances, open animosity while actively working for and favouring one set of candidates'.
28
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30
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G2. The Amici only wish to re-emphasize that this issue remains of
paramount concern to the realization of the Right to Vote guaranteed
by Article 59.
33
34
35
Besigye v. Museveni II, Judgment of Odoki CJ, pl53. Section 59 (6) (a) of the Presidential Elections Act, in
particular, which requires ~ petitioner to show that the irregularities complained about affected the results of the
election in a "substantial manner" came under particular scrutiny. For instance, Kanyeihamba JSC felt that it was an
unreasonable fetter on the power of the Supreme Court under Article 104 of the Constitution - see Besigye v.
Museveni ll, Judgment of Kanyeihamba JSC, at pp30 I, 304-306, ("In my considered opinion, Section 59(6){a) ... is
bad law"). On the other hahd, Katureebe JSC (as he then was) considered that this provision was legally valid Besigye v. Museveni Il, Judgment of Katureebe JSC, at pp.338-341, 347-350, 376 ("I see no inconsistency
whatsoever with provisions of Article I 04{1) ... the section 59(6)(a) of the Presidential Elections Act is not farfetched, and is certainly, in my view a reasonable ... provision").
37
Constitutional Petition No.l3 of2009.
38
Besigye v. Museveni J, J.udgment of Odoki CJ, p40.
Page 17 of 33
44
law."
Katureebe JSC (as he then was) emphasized the need for the
government to definitively address the issue of the involvement of security
forces in the electoral process. 45 lh hisview, although the government was
enj.oined to ensure security at all times, including during the election period,
the appropriate mea,gsrto.achieve this was by properly training and equipping
the tJ;g~nga Police '.Force:inwthisregard. 46 According to Justice Katureebe,
any other securityT!forces ix~ould . only be deployed, as a last resort, to
supplernent the police in the execution of its primary role. 47
Kl. It isJhe considered view of the Amici that the question of security is
both a capacity as well as a transparency-related issue. The Learned
Justices of the Supreme Court emphasized the need for effective
security. To achieve this, security needs to be considered at three levels:
(i) simple matters of low-level disturbance, which can be handled by
officials of the Electoral Commission; (ii) matters that pose a serious
threat to life and property over which the Commission has neither the
competence nor the capacity to handle; and (iii) insurrectionary
situations that threaten to destabilize the nation.
K2. The EC needs to be the first point of reference in all electionrelated security matters. Thereafter, the relevant security agencies can
be involved in the management of the issue recognizing that it is the EC
which takes the lead on all election-related matters.
44
As above.
Besigye v. Museveni II, Judgment ofKatureebe JSC, p402.
46
Besigye v. Museveni ll, Judgment ofKatureebe JSC, pp402-403.
47
Besigye v. Museveni ll, Judgment of Katureebc JSC, p403. See also, Besigye v. Museveni Il, Judgment of
Kanyeihamba JSC, p324, citing the partisan nature of, among others, the security forces including the police and the
UPDF 'to the extent of showing bias and, in some instances, open animosity while actively working for and
favouring one set of candidates'.
48
Besigye v. Museveni ll, Judgment ofKatureebe JSC, pp328-329.
45
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18. In additiori to the electoralreforms suggested by the Supreme Court in the 2001
and 2006 Presidential Election Petitions, there have been calls offered by different
actors for the comprehensive reform of the Electoral Commission (EC) and the
Many of these calls come from
general Presidential election processes.
independent election observers. Election observation is among the main quality
control mechanisms for any given cycle of elections. Election observation serves a
number of purposes including to: (i) enhance the public's confidence in the
electoral processes (ii) confirm legitimacy of the leaders elected out of the
processes (iii) expose shortfalls or any violations of civil and political rights that
may occur during the process, and (iv) produce reports with recommendations on
how to improve electoral laws and processes for future elections. 53 The Electoral
Commission Act gives the EC the mandate to accredit Election Observers who
participate in Uganda's elections in accordance with section 16 of the Act.
19. Elections Observers may be individuals, groups, or institutions, must carry out
their work in accordance with the guidelines for elections Observation or else they
commit an offence if they contravene the guidelines or observe without
accreditation. 54 Observation of elections without accreditation is an offence, which
on conviction, makes one liable to imprisonment for six months or a fine of a
maximum of fifteen currency points or both. 55 In Uganda's previous elections
(such as those of 2006 and 2011), a number of national organizations, 56
international bodies, and individuals were accredited to observe the elections. It is
a requirement of the law that at the end of the process, each observer or group must
issue a report to the EC within a period of six months after the results have been
declared. 57 Had the)( been implemented, these reports would have improved the
53
Office of the Special Adviser on Gender Issues and Advancement of Women (OSAGI), Women and Elections:
Guide to Promoting the Participation of Women in Elections, Chapter 7- Election Observation pages 75-86 at 75,
avai Iable at, http://www .un.org/womenwatch/osagi/wps/publication/Chapter7 .htm, accessed March 7th 2016.
54
Section 16 (3) & (4) ofthe Electoral Commission Act Cap. 140.
55
Ibid., Section 16 (6). Under the first Schedule to the Act, a currency point is UGX- 20000/=(Twenty thousand
Uganda shillings).
,
56
See, DEMGroup Long term Observation Finds Elections Mostly free but not fair, available at,
http://www.gndem.org/dommonreport DEMGroup LTOstatement 2011 eng, accessed March 7, 2016.
57
Cap. 140, Section 16 (5):
Page 21 of33
electoral processes of the 2016 elections cycle. It is our humble submission that
the Supreme Court should also give attention to the recommendations of these
actors, and compel the government to take seriously the recommendations of the
observers that it accredits in a bid to improve the electoral process.
20. This part ,of the briefaims at summarizing some of the proposals that have
emerged with . a firm belief that if implemented alongside the Supreme Court
recommendat1ons, they will set a secure and enduring basis for a free, fair,
transparent and effective.presidential electoral process.
21. Existence of an independent Electoral Commission is a pre-requisite for a free
andfair.election. The need for an impartial EC in Uganda has been acknowledged
Under the Constitution
by government and non,..govemment actors alike.
(Amendment) Bill of 2015 initiated by the Minister of Justice and Constitutional
Affairs, it was proposed that the name of the Commission be changed to the
Independent Electoral Commission (IEC). 58 Although eventually dropped and
excluded from the final text of the law as enacted by Parliament, this proposal
constituted an acknowledgement of the role of an independent electoral body by
59
government.
22. Prior to consideration of the Bill, the Uganda Citizens Compact on Free and
Fair Elections had made strong recommendations for the creation of a new
Electoral Commission. 60 This recommendation was also ignored by government
and subsequently the EC's structure and composition has remained unchanged
61
even as the country adopted a multi-party political system.
23. Still in relation to independence of the Commission, the Compact made a
recommendation to the effect that selection of Commissioners and staff of the
Commission should be subject to a process of open application, public hearing and
scrutiny by the Judicial Service Commission (JSC). 62 In addition to this proposal,
the staff and Commissioners were to be vetted by Parliament which on approval
would submit the , names of successful candidates to the President for
I
58
See Long Title and Clause ;I (a), Constitution (Amendment) Bill, No. 11 of2015.
59
See the Constitution (Amendment) Act, No. 12 of2015.
60
See Uganda Citizen Compact on Free and Fair Elections, Adopted at the National Consultation on Free and Fair
Elections, November 24-26,2014.
61
The Citizens Compact was an outcome of the National Consultation on Free and Fair Elections held between
November 24- 26, 2014. It incorporates the views of citizens as well as the different reform proposals made by
respectable groups such as the Citizens Coalition for Electoral Democracy (CCEDU), the lnterparty Political
Organizations for Dialogue (IPOD), the Electoral Commission (EC), National Consultative Forum (NCF) and
Cabinet. See Preamble to the Citizen Compact, p4.
62
See Para 1.1, Citizens Compact.
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appointment. 63
To date, the President maintains the right to appoint
Commissioners and Parliament's role is simply to approve names of those
appointed. 64 This greatly compromises the.desired independence and impartiality
of the Commission especially in an electoral process where the President is a
candidate. Tnrthis respect; 'there is also a need for clear regulations concerning the
use of sta.te resources 'in carnp(ljgns, the development of rules stipulating
"expenditure ceilings" on 1elect;jon campaigns and the passing of laws requiring
parties to give a detailed account of their financial resources and campaign
65
.
expen d Iture.
24. ln terms of tenure which is another important way of guaranteeing the
independence of individual Commissioners in the exercise of their duties, the
Citizens Compact recommended a seven year non-renewable term for
Commissioners.66 In addition, the Compact recommended that once in office
individual Commissioners were to only be removed on grounds of gross
misconduct or incompetence following the same criteria and procedure as is
applied in the removal of High Court Judges. 67
25. As it is, Commissioners are still eligible to serve for two (2) terms of seven
years and under the Constitutional Amendment Act, 2015, they may be removed
68
from office on recommendation of a tribunal appointed by the President. In cases
where any of the Commissioners is deemed unable to perform his or her functions
as a result of mental or physical incapacity, he or she may be removed from office
on advice of a medical board appointed by the President with the advice of the
head of Health Services. 69 The challenge with the current provisions is that the
President is still responsible for initiating removal proceedings and he also has the
mandate to appoint members of the tribunal and medical board. Secondly, where
Commissioners serve more than one term, there is a likelihood that they will act to
the whims of the appointing authority in order to secure reappointment. This also
grossly undennines their independence and that of the EC.
26. The other reform proposals made by the Citizens Compact and which have also
been raised by this honorable Comi in the 2001 and 2006 Presidential Petitions
63
!bid
See Article 60 {I) ofthe Constitution ofUganda as Amended.
65
The Commonwealth Observer group Report, at p40.
66
See Para 1.2, Citizens Compa~t.
67
Sec Para 1.3, Citizens Compact.
68
See Article 60 (9), Constitution of Uganda, 1995 (As Amended).
69
See Article 60 (10), Constitution of Uganda, 1995 (As Amended).
Page 23 of33
64
include the following: (a) none involvement of security forces and other militias in
the electoral processes; 70 (b) impartiality of the police in electoral processes and
their restricted role of upholding public order/ 1 (c) equal, fair and balanced
coverage of Presidential candidates by the media, 72 including the transformation of
the 1l:..Jgand(l \Broadcasting.. ,Corporation into an independent service broadcaster,
coupled :with the establi~hment of an independent broadcast complaints
commission? 3 and (d) cpmpilation of a new, clean and verifiable list of voters
through a. transparent process. 74 All the aforementioned proposals are critical for a
fair democratic process yet they are far from being implemented.
27. It is submitted before this honorable court that the continued disregard of and
non-implementation of the recommendations of the Supreme Court as well as
proposals for reform from the various stakeholders is responsible for the current
political stalemate. That stalemate has led to widespread dissatisfaction among
Ugandans with the outcome of the 2016 Presidential elections. It is further
submitted that if not addressed this growing dissatisfaction may not only increase
election disputes but also act as a precursor to serious conflict and even violence.
VI.
THE QUESTION OF ENFORCEMENT
28. However valid and incisive the views and decisions of the Supreme Court
on the conduct of the presidential elections, it is the considered view of your
Amici that the key question is whether those views and decisions are enforced.
To this end, two matters are key, first, the organs and agencies which are
responsible for the enforcement of those decisions, and secondly the
mechanisms used to enforce them. By way of addressing these issues, the
Amici wish to offer a legal perspective first of all on the role of the Attorney
General in the enforcement of decisions concerning presidential elections, and
secondly. on creative ways of using the mechanism of the Structural
Interdictllnj unction~
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31. It is thus the submission of your Amici that in light of the above, it only just
and proper that in reaching a decision in this Petition the honourable Supreme
Court takes into consideration the various proposals for legal reform it advised in
2001 and 2006 and to determine whether these reforms have been duly considered
and acted upon by the 3rd Respondent, i.e. the Attorney General. It is our humble
submission that this has not been the case, which explains the recurrence of issues
in t~e Petition which would have been avoided had the Jrd Respondent given the
Legislature and t~e Executi~e guidance for comprehensive reforms which fully
32. . The Amici su;bmit that the failure of the 3rd Respondent to guide the
Legislature an~ the Executive to effect the reforms suggested by this Honourable
Court h~s demed the country the chance to address the flaws in the electoral
sys~em m order to ensure that Presidential elections are conducted in a manner
whiCh ass~res. the people o~Ugan.da ofthe factthat consistent with Article 1(1) of
the ConstitutiOn P?~ers hes With them, in addition to Article 59(1) which
guarantees every Citizen above the age of 18 the right to vote. Indeed, it has
Page 25 of33
35. In addition to the provisions of Article 128(3), the inherent powers of this
Honourable Court derive from Section 98 of the Civil Procedure Act, Chapter 71
of Laws of Uganda, which provides that: Nothing in this Act shall be deemed to
limit or otherwise affect the inherent power of the court to make such orders as
may be necessary for the ends of justice or to prevent abuse of the process of the
court.
36. The Court can use these powers to retain jurisdiction in any case and to
demand a report bacl<- to it on any measures which a particular party has taken in
compliance with a 90urt directive. This is what is referred to as a structural
injunction/interdict. To borrow from an article by Dr. Christopher Mbazira:
I
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37. In Uganda, the Constitutional Court has recently found it fit to apply this
kind of relief in the case of Behangana Domaro & A nor v. Attorney General. 77 In
that case, the Court inter alia made the following order:
58. This case reveals significant misconduct of law enforcement
officers who ought to be prosecuted in accordance with the
Police 'Act. In order to address impunity we direct the
Registrar of this court to serve copies of this judgment upon the
76
Christopher Mbazira, "From Ambivalence to Certainty: Norms and Principles for the Structural Interdict in SocioEconomic Rights Litigatioi;~ in South Africa," Volume 28, No.l South African Journal on Human Rights (2008): I,
at p4.
77
Constitutional Petition No. 53 of 201 0.
Page 27 of 33
38. Irr\East Africa, the Kenyan .courts have led the way in using the structural
injunction. In the case dSatrose Ayuma & Ors V. The Registered Trustees Kenya
Railways Staff Retirement Scheme, 78 the Court, among others, made the following
order,
The 3rd Respondent shall within 90 days of this Judgment file
an Affidavit in this Court detailing out existing or planned State
Policies and Legal Framework on Forced Evictions and
Demolitions in Kenya generally and whether they are in line
with acceptable International standards.
following:
78
Petition No. 65 of201 0 Constitutional and Human Rights Division of the High Court of Kenya.
Page 28 of33
79
'
See Sibya & Ors v. DPP,' Johannesburg High Court & Ors 2006 2 BCLR 293 (Constitutional Court), available at
http://www.saflii.org/za/cases/ZACC/2005/6.pdf (accessed on 16th March 2016).
80
Liddle Lidd!e v. Board of Education of the City of St Louis 420 AFT AFL CIO. Also see Hart v. Community
School Board 383 F Supp 699 (EDNY 1974), available at http://caselaw.findlaw.com/us-8th-circuit/1195149.html.
(accessed on 16th March 20 16).
81
See Occupiers of 15 Olivia Road & Ors v. City ofJohannesburg & Ors 2008 5 BCLR 475 (Constitutional Court),
available at http://www.saflii.org/za/cases/ZACC/2008/J.html, (accessed on 16th March 2016).
82
Pennsylvania AssociatiQn of Retarded Children v. Pennslyvania 334 F Supp 1257 (ED Pa 1971 ), available at
http://www.leagle.com/decision/1971 1591334FSupp1257 11361/PENNSYLVANIA%20ASS'N.%20RETARD.%2
OCHILD.%20v.%20COMMONWEALTH%200F%20PA (accessed on 16th March 2016).
Page 29 of33
83
Myriarn Gilles, "An Autqpsy of the Structural Reform Injunction: Oops ... It's Still Moving," Vol.58 University of
Miami Law Review (2003), at p\43.
84
Brian K. Landsberg, "Does Prison Reform Bring Sentencing Reform? The Congress, the Courts and the
Structural Injunction," Vol.46 McGeorge Law Review (2014): 749-774.
Page 30 of 33
n.
iii.
iv.
b)
c)
d)
e)
f)
g)
h)
i)
j)
k)
I)
in)
Page 32 of33
J. OLOKA:LONYANGO
SYLVIA TAMALE
CHRISTOPHER MBAZIRA
RONALD NALUWAIRO
ROSE NAKAYI
BUSINGYE KABUMBA
I,
-KAKUNGULU MA YAMBALA
DANIEL NGABIRANO
'
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