THE REPUBLIC OF UGANDA
IN THE HIGH COURT OF UGANDA HOLDEN AT KAMPALA
MISCELLANEOUS CAUSE NO. 194 OF 2011
[Under SS 14 (2) (c), 33 & 39 of the Judicature Act Cap 13, SS 3 & 4 of the
Judicature Amendment Act 2002, S 98 of the CPA and Order LII rr 1, 2 of the
CPR]
1. BENON MUHANGUZI
:::::::::::::::::::::::::::::::::::::APPLICANTS
2. LAZARUS AGORO
VESUS
UGANDA PEOPLES CONGRESS:::::::::::::::::::::::::::::::::::::RESPONDENT
AFFIDAVIT OF SERVICE AND IN ADDITION
I, Krispus Charles Ayena Odongo of C/o Ms Ayena Odongo Co. Advocates, Rajja
Chambers, Plot 4 Rooms 059/60 Parliament Avenue, P.O.Box 2818, Kampala, do
hereby solemnly swear and state as follows:
1. That I am an adult male Ugandan of sound mind and the Counsel in
personal conduct of the above Application and therefore competent to swear
this Affidavit.
2. That on the 6th April 2012, on the instruction of UPC Party officials
and members concerned about the confusion in the party; and because of the
matters in court in the above Application I proceeded to the Headquarters of
the Respondent in the company of Mr. Sospata Akwenyo (a respondent party
Cabinet member and former aspirant for the party presidency), Dr. Luwero
(former aspirant for the party presidency), to serve a Petition signed by
members of the Annual Delegates Conference calling upon the Party President
to call a Special Delegates Conference within one week of service of the
same upon him.
3. That, being a former senior officer of the Milton Obote Foundation and
presently member of Parliament on the UPC ticket, and indeed a member of the
National Council, I know the party secretariat where the Party President has
offices on the 6th floor of Uganda House on Plot 8/10, Kampala Road.
4. That when we arrived at Uganda House my entourage was met with hostile
reception by secretariat staff of the party, led by one Romano Okello, who
initially prevented us from entering the offices of the party secretariat.
5. That, however, after a long spell of explanation and insistence three
of us Mr. Sospata Akwenyo, Dr. Luwero and Dr. Kawada and I - were allowed
in.
6. That we were met by the above mentioned Romano Okello who introduced
himself as an Assistant Secretary at the secretariat and another who
introduced himself as Charles Ojok, the office superintendent at the same
secretariat.
7. That after explaining the purpose of our visit to the Party Secretariat
Mr. Romano Okello went to meet the Party President and came back to inform
us that the Party President would not meet us as he was preparing to meet
party officials from the Buganda region who were already assembled in the
Conference room.
8. That when we insisted and told them that our purpose was not to meet
the Party President but to serve the Petition on him, which did not need
more than him just receiving and signing a copy of the same, the next thing
we saw was a squad of police officers led by the DPC of CPS who told us that
the Party President had invited them saying the party Headquarters had been
invaded by people who were causing commotion at the Party secretariat.
9. That when we explained the purpose of our visit to the police officers
they appreciated and, in their full view, we left a copy of the Petition and
the Motion signed by members of the partys National Council for debating
and passing a Vote of No Confidence in Ambassador Olara Otunnu as the Party
President. Photocopies of the Petition and Motion are hereto attached.
10. That the provision of Article 13.3 (4) compels the Party President to
call a Special Delegates Conference when petitioned by more than half of
the members of the Annual Delegates Conference signing the Petition
calling upon him to call a Special Delegates Conference. In this case
more than 600 out of 1005 members of the Delegates Conference have signed
the Petition.
11. That the Petition now reinforces the grounds of the above Application
calling, among other things, on the Party President to call for the
Delegates Conference on the terms contained in the Petition and hence
this Affidavit is also sworn in further support of the grounds of the
Application.
12. That in the circumstances it would be in the interest of justice for
this honourable court to grant the orders prayed for.
13. That what is stated herein is true and correct to the best of my
knowledge, information and belief wherever it is so stated expressly or by
necessary inference.
SWORN at Kampala by me, the said K.C Ayena Odongo
this....................Day of ..................2012.
___________
DEPONENT
BEFORE ME: ________________________
COMMISSIONER FOR OATHS.
DRAWN & FILED BY:
Ms Ayena Odongo Co. Advocates,
Rajja Chambers,
Plot 4 Rooms 059 Parliament Avenue,
P.O.Box 2818, Kampala.
Thé Mulindwas Communication Group
"With Yoweri Museveni and Dr. Kiiza Besigye Uganda is in anarchy"
Kuungana Mulindwa Mawasiliano Kikundi
"Pamoja na Yoweri Museveni na Dk. Kiiza Besigye Uganda ni katika machafuko"
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