High Court orders estate account before renewing administration of late Muhakanizi’s estate

The High Court Family Division in Kampala has ordered the administrator of the estate of the late Muhakanizi Keith to file a full account of the estate within one month as a strict condition for the renewal of Letters of Administration.

In a detailed ruling delivered on March 31, 2026, Lady Justice Celia Nagawa made it clear that no extension of the grant will take effect unless the administrator first complies with the statutory requirement to account for her stewardship of the estate.

“The Applicant should first file an account of the estate of the Late Keith Muhakanizi within one month from the date of this Ruling, accounting for the period she had the Letters of Administration,” the judge directed.

The application, filed by Janet Kamukama Muhakanizi, arose after the initial grant issued on November 17, 2023 expired on November 17, 2025 before the estate had been fully administered. She sought a two year extension to complete outstanding processes, including access to pension benefits from the Ministry of Public Service, transfer of shares in several companies, and processing of a special land title.

Court records show that while the administrator filed an inventory in May 2024, she had not filed the mandatory estate account as required under Section 273(1) of the Succession Act. The court found this omission central to determining whether the grant could be extended.

Justice Nagawa emphasized that compliance with the law is a foundational requirement, not a formality.

“Compliance with the provisions of the Act or any condition to which the grant of letters of administration is subject to is one of the conditions required… before the Court may extend the validity of Letters of Administration,” she ruled.

The judge examined the legal threshold under Section 256 of the Act, which allows extension of a grant only where it is in the best interests of the beneficiaries and where the administrator has fulfilled statutory obligations, including obtaining consent from all beneficiaries.

In this case, the court confirmed that all beneficiaries, including the widow and the deceased’s three children, had signed consent supporting the application.

“This Court finds that it is in the best interest of the beneficiaries to grant this Application,” the judge noted.

However, the court was equally critical of gaps in the administration of the estate. It pointed out that some assets, including shares in companies such as UMEME, Bank of Baroda, New Vision and SBG Securities, had not been disclosed in the original petition, raising concerns about full disclosure and proper management of the estate.

The court also acknowledged that key aspects of the estate remain unresolved, including accessing employment benefits and completing land title processing for property located at Block 74 Plot 17 in Kabula, all of which require a valid subsisting grant.

Despite these considerations, the judge declined to grant an outright renewal, instead issuing a conditional order that places accountability at the centre of the process.

“Upon satisfactory compliance with the above order, renewed Letters of Administration shall be granted to the Applicant for a further period of two years for purposes of pension and for a further period of two years in respect of the non-pension assets of the estate,” the ruling states.

The court further clarified that the extension will operate in two distinct tracks, separating pension matters from non-pension assets, each to run for a period of two years upon compliance.

In closing, the court made no order as to costs.

“No order as to costs,” Justice Nagawa held.

The High Court insists that administrators must strictly comply with statutory duties, particularly the obligation to account, before they can be allowed to continue managing estates.