Court upholds conviction of former Gulu clinical officer over forged academic transcript
In a judgment delivered at Kampala on October 30, 2026, Deputy Chief Justice Moses Kawumi Kazibwe, alongside Justices Margaret Tibulya and Musa Ssekaana, found no merit in the six grounds of appeal raised by Labong.
The Court of Appeal also rejected the challenge to the admission of the charge and caution statement, noting that defence counsel had indicated that there was no objection when the prosecution sought to tender it in evidence.
KAMPALA - The Court of Appeal has upheld the conviction and sentence of a former senior clinical officer of Gulu Municipal Council who was convicted of uttering a false academic transcript to secure admission to study human medicine at Gulu University.
The court dismissed an appeal filed by William Kenneth Labong, who had challenged his conviction and sentence of a fine of sh1m or two years’ imprisonment in default.
In a judgment delivered at Kampala on October 30, 2026, Deputy Chief Justice Moses Kawumi Kazibwe, alongside Justices Margaret Tibulya and Musa Ssekaana, found no merit in the six grounds of appeal raised by Labong.
The appeal arose from a decision by High Court Judge Tonny Vincent Okwanga, who upheld Labong’s conviction by the lower court in a judgment delivered on January 7, 2019.
Court records indicate that Labong was employed as a senior clinical officer with Gulu Municipal Council before applying and gaining admission to Gulu University to study human medicine during the 2010/2011 academic year.
He was registered under index number U0837/518 after submitting academic transcripts from Gulu School of Clinical Officers in support of his application.
However, the Office of the Inspectorate of Government (IGG) later initiated investigations into the authenticity of the academic documents he had presented to the university
The IGG, through the university’s academic registrar, requested Labong to submit his original academic documents for verification.
Two days after receiving the communication, on October 10, 2011, Labong wrote to the academic registrar seeking to withdraw from the diploma programme, citing a heavy workload
On November 1, 2011, Labong recorded a charge and caution statement in which he admitted forging the academic transcript from Gulu School of Clinical Officers to secure admission to the university
In the statement, he reportedly said he had joined the school in 1998 and completed his studies in April 2002, obtaining pass grades which did not qualify him for admission to a government university to pursue human medicine.
He was subsequently charged with two counts of uttering false documents under sections 351 and 347 of the Penal Code Act.
He was convicted on the first count and sentenced to pay a fine of sh1m or serve two years in prison in default
Dissatisfied with the conviction and sentence, Labong appealed to the High Court, which upheld the decision, prompting his appeal to the Court of Appeal.
In his appeal, Labong argued that the lower courts had upheld his conviction without sufficient evidence linking him to the falsification of the academic transcript
He also challenged the reliance on circumstantial evidence, arguing that the courts had failed to establish that he knew the document was false when he submitted it to the university
On the charge and caution statement, his lawyer, Timothy Niwamanya, argued that the trial court had admitted and relied on the statement after the defence indicated that it had no objection, without first establishing whether Labong had voluntarily made it.
However, Assistant Director of Public Prosecutions Simon Peter Semalembe represented the State and opposed the appeal.
The justices observed that the prosecution had established that Labong personally submitted the questioned transcript to Gulu University to secure admission.
They also considered evidence from Tadeo Mulumba, a witness from Gulu School of Clinical Officers, who testified that the grades appearing on the transcript did not correspond with the school’s official academic records
According to the court, the records showed that Labong obtained pass grades in 2002, whereas the transcript he submitted reflected 28 points.
The justices held that the prosecution was not required to prove that Labong personally forged or physically altered the document to secure a conviction for uttering a false document under section 351 of the Penal Code Act
They explained that the prosecution was required to prove that the document was false and that the accused knowingly and fraudulently presented it as genuine.
On the circumstantial evidence, the court considered Labong’s withdrawal request, which he submitted two days after the IGG had requested verification of his academic qualifications.
The justices found that his conduct, together with the evidence concerning the discrepancies in the transcript, established that he knew the document was false.
The court also rejected the challenge to the admission of the charge and caution statement, noting that defence counsel had indicated that there was no objection when the prosecution sought to tender it in evidence.
The justices further found that the High Court had properly re-evaluated the evidence, including the testimonies of prosecution witnesses and the documentary exhibits, before upholding the conviction.
Consequently, the Court of Appeal dismissed the appeal against both conviction and sentence.