THE REPUBLIC OF UGANDA
IN THE CHIEF MAGISTRATES COURT OF KAMPALA AT BUGANDA
ROAD
CRIMINAL MISC.CAUSE NO………………………OF 2024
ALLAN
KINYAMATAMA::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::: APPLICANT
VERSES
1. UGANDA
2. INSPECTORGENERALOF
POLICE:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::RESPONDENTS
NOTICE OF MOTION
(Under Article 23(4)(b) , 50(1,2,3), of the 1995 Constitution and Section 25(1)(2) of the
Police Act Cap 324 As Revised).
TAKE NOTICE that this Honorable Court shall be moved on the…………..day
of……………..2020 at……………….am/pm or soon thereafter as Counsel for the applicant
shall be heard on the following orders;
a) That the applicant currently detained at Kampala Metropolitan Police (CPS) be
unconditionally released from custody upon Court Order.
b) That this honorable Court makes such orders as is deemed just for enhancement of
justice.
c) That costs of this application be in the cause
TAKE FURTHER NOTICE That this application is brought by way of Notice Of Motion
supported by an affidavit of MR. KIIGE ABDALLAH (counsel for the applicant) stating the
grounds which shall be relied upon at the hearing but briefly include;
a) That the applicant was arrested on the 6 th day of November 2024 at
……………………..and has been in state house Anti-Corruption Unit up to date.
b) That the applicant has since been denied police bond and not charged with any offence in
any courts of law.
c) That it is just and equitable that this court grants unconditional release of the applicant.
Dated at Kampala this…………………day of………………………………2024
...............................................................................
REGISTRAR
DRAWN & FILED BY:
Matovu,Katerega & Co.Advocates
Explorer suites, Suite 7 Plot 92,
William Street,
P.O BOX 11586
KAMPALA.
THE REPUBLIC OF UGANDA
IN THE CHIEF MAGISTRATES COURT OF KAMPALA AT BUGANDA ROAD
CRIMINAL MISC.CAUSE NO………………………OF 2024
ALLANKINYAMATAMA:::::::::::::::::::::::::::::::::::::::::::::: APPLICANT
VERSES
1. UGANDA
2. INSPECTOR GENERAL OF
POLICE:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::RESPONDENTS
AFFIDAVIT IN SUPPORT
I KIIGE ABDALLAH of Matovu, Katerega & Co.Advocates Explorer suites, Suite 7 Plot 92,
William Street, P.O BOX 11586 KAMPALA having gotten instructions from the family of the
accused do solemnly swear as follows;
1. That I am a male adult Ugandan of sound mind and Counsel for the Applicant in which
capacity I swear this Affidavit.
2. That my Client was arrested by the state house Anti-Corruption Unit from Kampala on the 6 th
day of November 2024 on charges of Malicious Damage to property and Criminal Trespass
3. The Applicant has since been detained at Kampala Metropolitan( CPS)Police Custody right
from his time of arrest on 6 th of November 2024 up to date which is beyond 48 hours without
being released on police bond as well as being presented to any Court for trial which
contravenes both Section 38(1) and Article 23(4)(b) of the Police Act Cap 324 and 1995
constitution of the Republic Of Uganda respectively.
4. The Applicant has never been presented before any Honorable Court for trial contrary to
Article 23(4)(b) of the 1995 constitution of the Republic Of Uganda .
5. The Applicant up to date remains incarcerated in Police Custody without trial for No good
cause whereby the Applicant’s Constitutional rights such as personal liberty, right to speedy trial
by Court has been violated.
7. It is just and equitable that the Applicant be released unconditionally.
8. That whatever I have stated herein is true to the best of my Knowledge and belief.
Signed by the said.
COUNSEL KIIGE ABDALLAH
………………………………………………………..
DEPONENT
……………………………………………………………..
COMMISSIONER FOR OATHS
DRAWN & FILED BY;
Matovu,Katerega & Co.Advocates
Explorer suites, Suite 7 Plot 92,
William Street,
P.O BOX 11586
KAMPALA.
