Lukanda v Birungi [2011] EWCA Civ 1520 (17 November 2011)

The CA allowed an appeal in respect of nullity proceedings. A significant disputed element in the hearing below was a certificate which puported to be a Ugandan marriage certificate. The CA held that given that this was on the face of it authenticated by various Ugandan authorities it should have been presumed to be valid and the burden fall on the party seeking to show it was not valid. The matter was remitted for re-hearing as these issues had not been considered below.