120 Kabumba/Application of African Union (human rights) law in Uganda court. However, in his own determination of the point, the High Court Judge did not rely on this case. In Legal Brains Trust (LBT) Ltd v Attorney General and National Council of Sports,214 another 2014 High Court case, counsel for the respondent relied on the EACJ decision in Timothy Alvin Kakkoko v the Secretary General of the East African Community215 to contend that, in determining the award of a temporary injunction, a Court had to be satisfied that the applicant had a prima facie case with a likelihood of success. Again, in determining the matter, the High Court did not rely upon this authority. The trend of judicial avoidance of EACJ jurisprudence was further evident in 2015 High Court case of National Oil Distributors Ltd v Attorney General.216 In that matter, counsel for the respondent cited the EACJ’s decision in East African Law Society217 with regard to the nature of an interlocutory order, as distinct from a final order. Once again, however, in determining the question, the High Court Judge did not himself depend upon this authority. Most recently, in the 2016 High Court case of Hon. Acire Christopher v Hon Okumu Reagan Ronald and Electoral Commission218 counsel for the first respondent referred to the case of Sitenda Sebalu219 relating to contempt of court for non-compliance of court orders and stipulated that in the instant case, no contempt could arise as the first respondent had not been obligated to do any act by the orders in question. However, in determining the matter, the High Court did not expressly rely on this authority. The division in Ugandan jurisprudence regarding the reception of EACJ case law appears to run right down the middle: of the ten cases in which EACJ case law was cited, in five cases the courts relied on the EACJ authorities, while in the other five, the courts appear to have ignored those authorities. The apparent deadlock might be broken in favour of judicial indifference to EACJ case law, when it is considered that on the one hand, three of the five pro-EACJ decisions (Kabaza, Akidi and Toolit) were rendered by the same Judge – Opio Aweri, while on the other hand, of the five EACJ-neutral decisions, only two (Katuntu and National Oil) were by the same Judge – Izama Madrama. As such, it could be said that, on balance, however slight, Ugandan courts have been more indifferent than receptive to EACJ jurisprudence. 214 215 216 217 218 219 High Court Misc Appln No.638 of 2014, arising out of Misc Cause No.54 of 2014 (Ruling of Judge Elizabeth Ibanda Nahamya). Application 5 of 2012. High Court Misc Cause 241 of 2015 (Ruling by Judge Christopher Izama Madrama). n 213. Election Petition 4 of 2016 (decision of Judge David Matovu). n 207.