Thursday, March 31, 2022

CUSTODY OF CHILDREN IN FAMILY MATTERS IN UGANDA

 CUSTODY

Section 1(q) of the Children Act as amended defines a custodian as a person in whose care a child is physically placed. Custody concerns the legal rules governing the right of children regarding who to live with.

Any harm that the child has suffered or is likely to suffer or is at the risk of suffering; and where relevant, the capacity of the child's parents, guardian or any other person involved in the Care of the child, and in meeting the needs of the child.

In Rwabuhemba Tim Musinguzi v Harriet Kamakume Court of Appeal Civil Application No.142 Of 2009, Held; Parents have a fundamental right to care and bring up their children. This is a constitutional right. Of course it is not considered in isolation. The welfare of the child is a consideration to be taken into account, and at times may be the paramount consideration. A parent can only be denied the right to care for and raise her children when it is clear and has been determined by a competent authority, in accordance with law, that it is the best interest of the child that the child be separated from the parent

For one to get granted custody there are a number of factors that have to be considered.

Welfare of the child

 S.73 (3) of the Act, the court shall primarily consider the welfare of the child. Section 3 of the children Act, as amended provides that the guiding principle is the child’s welfare which is paramount. It provides that the welfare principle shall be the guiding principle in making any decision based on this Act.

In Hassan Mariam Mohammed (1977) HCB 43; it was held that the welfare of the children is a paramount consideration and the matter of custody is best determined after hearing both parties and custody should not be granted until both parties have been heard.

 

Children of tender years

 It is presumed that children of tender years that is 7years and below should live with their mother as opposed to the father.

Teopista Kayongo v Richard Sekiziyivu (1978) HCB 240. It was held that as concerns children of tender years, such children should normally stay with their mother unless she is not a fit and proper person. And where the custody of the children is taken away from their mother, the mother should be free to visit her children as often as she pleases.

Better financial status

 Hofman v Hofman (1970) E.A. 100 court held that although the father’s superior financial position over the mother was irrelevant in custody cases, it could not be ignored, if it could be proved that the father could use his superior financial position to cater for the welfare of the child better than the mother whose financial inferiority would stand in her way, the overriding factor is the interests of the child and if the father could use them to enhance the welfare of the child, it could be taken into consideration.

Conduct of the parties

 Nyakairu v Nyakairu court held that in applying the welfare principle court had to consider other ancillary circumstances e.g. such matters as; who of the spouse was to blame for the breakup of the marriage, who of the spouses was more financially equipped to look better after the interests of the children and which spouse could provide a more comfortable home. Court held that immorality on the father was not sufficient justification for interfering with the common law right of custody of children unless such immorality was very flagrant or was coupled with other habits injurious to the children.

Variation of custody.

According to Section 85of the Act, where the court is satisfied on information from a parent  or an official of a local government council that the parent who has custody of the child is wilfully neglecting or mistreating the child, custody shall be granted to the other parent[CT1] .

The Queen v Gungail (1893) 2 QB 233 at 243, the court is placed in a position of reason. In its prerogative to act as a supreme parent of the children and must exercise its jurisdiction in a manner which a wise affectionate and careful parent would act for the welfare of the child

Custody maybe joint or sole following Section 73(1), the court may on the application of a sole applicant or joint applicants, grant custody of a child on such conditions as may be determined by the court. Sec.73 (2) Provides that the court may at any time revoke the grant of custody to one person and make the grant to another person, institute or organization. Sec.73 (3) of the Act provides that the in reaching its decision under sub section (1) and (2), the court shall primarily consider the welfare of the child.

Procedure:

Rule 19(3) of the Children (Family and Children Court) Rules provides that an application for a custody order shall be specified in Form 1 in the schedule to the rules and rule 19(1) provides that the application shall be supported by an affidavit, and any reports or documents to be relied upon shall be attached to the application.

 

Interim Custody.

Section 73A of the Children Act as amended provides for interim custody order. 73(1) a probation and social welfare officer, mother father or guardian of a child may apply to the family and children court for an interim custody order pending the determination of custody of the child by court. 73(2) of the Children Act as amended provides that the application for an interim custody shall be supported by affidavit of the applicant. 73(3) of the Children Act as amended provides that the court may issue an interim custody order may, where the court is satisfied that,

(a)  The child is suffering or likely to suffer harm if the order for the interim custody is not issued.

(b)  The order is in the best interest of the child.

(c)  An interim custody order may, where appropriate, contain any direction, prohibition or award.

Custody by Agreement.

S. 73B of the Children Act as amended provides for custody by agreement.

73B (1) of the Children Act as amended explains that the parents of a child may enter into a written agreement to determine which of them shall have custody of the child. 73B(2) of the Children Act as amended provided that court may recognise an agreement made between the parents of a child giving the custody of the child to one of the parents, except where court finds that enforcing the agreement would not be in the best interest of the child.

73B (3) court shall only recognise an agreement under subsection (1) if it is satisfied that there was no duress or fraud involved in making the agreement.


Variation of custody.

 [CT1]Applicable to our facts.? 

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