Akankwasa v Equity Bank (Labour Dispute No. 302 of 2014)
Observed later treatment
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Holding
The Industrial Court held that termination of employment without stating reasons and without affording the employee a hearing violates sections 66 and 68 of the Employment Act 2006, rendering the termination both substantively and procedurally unlawful. An employer must explain the reason for contemplated dismissal and hear the employee's representations before reaching a decision to terminate, even where termination is purportedly exercised under contractual rights. The claimant was awarded general damages and severance pay.
Outcome
Claimant's employment termination declared unlawful; awarded general damages and severance pay with interest
Facts
On 23 November 2011, the claimant was employed by Equity Bank as Business Growth Development Manager earning UGX 3,300,000 per month and posted to Kabale as Branch Manager. In May 2013, he received communications alleging poor performance and failure to meet targets. On 10 October 2013, he was placed on a one-month performance improvement plan. On 17 July 2013, he was issued a termination notice that did not state any reason for termination. The claimant alleged the termination was wrongful because the bank did not follow procedures in its Human Resources Policy Manual, did not give him opportunity for redeployment, and terminated him abruptly without opportunity to maximize his potential. The respondent contended it exercised its contractual right to terminate with notice and that no hearing was required because the termination was not based on poor performance allegations.
Issues
- Whether the termination of the claimant's employment was fair and lawful?
- What remedies are available to the parties?
Orders
- A declaration that the claimant was unlawfully terminated.
- An award of UGX 9,600,000 as general damages.
- An award of UGX 4,950,000 as severance pay.
- Interest of 18% per annum on general damages and severance pay from date of judgment until payment in full.
- No order as to costs.
Rules and key headnotes
Legislation cited (11)
Cases cited (17)
- Turyatemba v Attorney General (Constitutional Petition No. 15 of 2006)
- Kagwa v Plan International (Labour Dispute No. 175 of 2014)
- Mufumbo v Uganda Development Bank (Labour Dispute No. 138 of 2014)
- Mukooli v The New Forest Co. Limited (High Court Civil Suit No. 173 of 2008)
- Nassanga v Stanbic Bank (Labour Dispute No. 227 of 2014)
- Akeny v Uganda Communications Commission (Labour Dispute No. 023 of 2015)
- Stanbic Bank v Kiyemba Mutale (Supreme Court Civil Appeal No. 2 of 2010)
- Musinguzi v Stanbic Bank (Supreme Court Civil Appeal No. 5 of 2016)
- Okuo v Stanbic Bank (Labour Dispute No. 171 of 2014)
- Edace v Watoto Child Care Ministries (Labour Dispute Appeal No. 16 of 2015)
- African Field Epidemiology Network v Kityaba (Court of Appeal No. 124 of 2017)
- Kapio v Centenary Bank (Labour Dispute No. 300 of 2015)
- Obonyo & Another Vs Municipal Council of Kisumu 1971(EA,)
- Ahmed Ibrahim Bholm Vs Car & General
- Kamuli v DFCU Bank (Labour Dispute No. 002 of 2015)
- Adetoun Oladeji (NIG) vs Nigeria Breweries PLV+C S.C, 91/2002
- Independent Electrol and Boundaries Commission and anor vs Stephen Mutinda Mule & 3 others CA
Cases citing this judgment (1)
How later Ugandan judgments in the Wakilii corpus have cited this case. Treatment labels come from Sequitur — Uganda’s citator — each backed by a verbatim span from the citing judgment, and are not an assertion that this case is, or is not, good law.
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.