Wakilii

AC Yafeng Construction Company Limited v Living Word Assembly Limited and Others (Miscellaneous Application No. 2883 of 2025)

High Court · [2026] UGCOMMC 220 · 2026 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for discovery arising from civil suit for fraud and breach of contract
Decision
Application for discovery dismissed

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The High Court dismissed an application for discovery of correspondence and bank statements in a fraud and breach of contract suit. The court held that the applicant's request was speculative and amounted to a fishing expedition, as the existence and possession of the sought documents could not be verified. The court further held that ordering disclosure of bank statements risked violating the respondents' constitutional right to privacy under Article 27(2) where the transactions were not proven to relate solely to the contract in dispute.

Outcome

Application for discovery dismissed

Facts

On 16 September 2019, the applicant construction company entered a contract with the first respondent church to construct a 10,000-seater prayer city project. The applicant provided performance and advance payment guarantees totalling over UGX 10 billion through the third respondent bank. On 24 December 2020, the first respondent terminated the contract. The first respondent then called on both guarantees and the third respondent paid out over UGX 10 billion on 19 March 2021, after an interim injunction was vacated. The applicant filed a main suit alleging fraud, conspiracy, and breach of fiduciary duty. In this interlocutory application, the applicant sought discovery of correspondence between the respondents and bank statements to prove the alleged conspiracy and the first respondent's lack of financial capacity. The respondents filed no affidavits in reply.

Issues

  1. Whether the Court should grant an order for the discovery of the documents?
  2. What remedies are available to the parties?

Orders

  • Application dismissed.
  • No order as to costs.

Rules and key headnotes

Discovery — Prerequisites for Grant of Order
An order for discovery will only be granted where the applicant establishes that the documents sought are relevant and material to the matters in issue, not privileged or protected by law, in the respondent's possession or power, and that attempts to obtain them voluntarily were futile.
Discovery — Materiality of Documents
A document is material if it is offered to prove an element of a claim or defence that must be established for one side to prevail. The applicant must show a reasonable expectation that the material sought will aid in the resolution of the suit.
Discovery — Fishing Expeditions
Discovery must not be misused as a fishing expedition for an applicant to establish an uncertain case. Where the existence and possession of sought documents cannot be verified and the request is speculative, the court will refuse the order for discovery.
Right to Privacy — Discovery of Bank Statements
An order for discovery of bank statements that would expose a party's dealings with clients other than the applicant, where those transactions are not proven to relate solely to the contract in dispute, risks violating the constitutional right to privacy under Article 27(2) of the Constitution.

Legislation cited (13)

Cases cited (8)

  • AKT Project Management Limited and 2 Others v DFCU Bank Limited (2024 UGCommC 248)
  • Simbamanyo Estates Limited & Another v Equity Bank Uganda Limited and 4 Others (Miscellaneous Application No. 583 of 2022)
  • Dresdner Bank AG v Sango Bay Estates Ltd (No.4) [1971] 1 EA 409
  • John Kato v Muhlbauer A.G and Another (High Court Miscellaneous Application No. 175 of 2011)
  • William Akankwasa v Registrar of Titles (HCMA No. 33 of 2008)
  • John Bwiza v Patrick Yowasi Kadama (Court of Appeal Civil Appeal No. 35 of 2011)
  • Patricia Mutesi v Attorney General (HCMA No. 912 of 2016)
  • Kaweesi Sulaiman and 26 Others v Bank of Uganda and Another (HCMA No. 258 of 2022)

Full judgment

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The original judgment as reported. Read the original PDF before relying on any passage.

AC Yafeng Construction Company Limited v Living Word Assembly Limited and Others (Miscellaneous Application No. 2883 of 2025) [2026] UGCommC 220 (7 April 2026)
Source: this page presents Wakilii’s issue analysis and metadata for a publicly reported Ugandan judgment. Any AI-generated summary is marked as such. Judgment text is sourced from the Uganda Legal Information Institute (ulii.org). Wakilii is not affiliated with ULII.