Annette Najjemba v MK Publishers Limited (Civil Suit No. 508 of 2016)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The High Court held that MK Publishers Limited infringed both the copyright and moral rights of author Annette Najjemba when it altered, reproduced, and sold four of her children's stories as audio series to the Government of Rwanda without her written authorization, licence, or assignment, and without acknowledging her authorship. The court awarded 30% royalty fees, general damages of UGX 70 million, exemplary damages of UGX 30 million, and issued a permanent injunction restraining further infringement.
Outcome
Judgment entered for the Plaintiff with declarations of copyright infringement, monetary awards, and permanent injunction issued
Facts
In 2010, Annette Najjemba authored a manuscript titled 'Our Folktales' containing six children's stories. In 2012, she submitted a tweaked abridged version to MK Publishers Limited for publishing. In 2013, she discovered that the Defendant had, without her authorization, altered four of her stories to fit Rwandan culture, reproduced them as audio stories for Primary Five and Six, and sold them to the Government of Rwanda under a contract dated 15 December 2012. The audio story jackets bore the Defendant's insignia as author, not the Plaintiff's. The Defendant attributed the stories to itself and did not acknowledge the Plaintiff as author. The Defendant claimed implied consent from the Plaintiff's submission of the manuscript, but admitted no written licence, assignment, or transfer existed, and that the Plaintiff was never paid for the work sold to Rwanda.
Issues
- Whether the Defendant infringed on the Plaintiff's copyright?
- What remedies are available to the parties?
Orders
- It is declared that the Plaintiff's copyright and moral rights of her literary work comprised in a manuscript titled 'Our Folktales' were infringed on by the Defendant.
- The Defendant is ordered to pay 30% royalty fees for profits arising out of the sales of the 'VCD-MK audio stories Primary Five' and 'VCD-MK audio stories Primary Six'.
- A permanent injunction is issued against the Defendant, its agents and employees from further dealing in the Plaintiff's literary work titled 'Our Folktales'.
- The Plaintiff is awarded general damages amounting to UGX 70,000,000.
- The Plaintiff is awarded exemplary damages amounting to UGX 30,000,000.
- The Plaintiff is awarded interest at the rate of 24% per annum on the royalty fees from the date the cause of action arose until payment in full.
- Interest is awarded at the rate of 6% per annum on the general and exemplary damages from the date of Judgment until payment in full.
- The Plaintiff is awarded the costs of the suit.
Rules and key headnotes
Legislation cited (12)
- Copyright and Neighbouring Rights Act Cap. 222 s.3
- Copyright and Neighbouring Rights Act Cap. 222 s.4
- Copyright and Neighbouring Rights Act Cap. 222 s.8
- Copyright and Neighbouring Rights Act Cap. 222 s.9(1)
- Copyright and Neighbouring Rights Act Cap. 222 s.13
- Copyright and Neighbouring Rights Act Cap. 222 s.44
- Copyright and Neighbouring Rights Act Cap. 222 s.45
- Evidence Act Cap. 8 s.101
- Evidence Act Cap. 8 s.102
- Evidence Act Cap. 8 s.103
- Civil Procedure Act Cap. 282 s.26(2)
- Civil Procedure Act Cap. 282 s.27(2)
Cases cited (14)
- Knight Frank Uganda Ltd v Broll Uganda Ltd & Another (High Court Civil Suit No. 206 of 2021)
- Sawkins Vs Hyperion Records Ltd [2005] EWCA Civ. 565
- Stella Atal v Ann Abels Kiruta (High Court Civil Suit No. 967 of 2004)
- Sebuliba Busuulwa Vs Co-operative Bank Ltd [1982] HCB 129
- Zeenode Limited v The Attorney General & 2 Others (High Court Miscellaneous Application No. 347 of 2021)
- Francis Day and Hunter Limited Vs Twentieth Century Fox Corporation Limited & Others [1940] AC 112
- Ravenscroft Herbert Vs New English Library Limited [1980] RPC 193-212
- Bwavu Mpologoma Growers' Co-operative Union Limited Vs Gasston and Barbour & Others [1959] EA 307
- Obsessions Company Ltd v Warid Telecom (High Court Civil Suit No. 373 of 2010)
- Garfield Spence v Airtel Uganda Limited & Others (High Court Civil Suit No. 545 of 2015)
- Luzinda Marion Babirye v Ssekamatte (Alias Mulwana Samuel) & Others (Civil Suit No. 366 of 2017)
- Obongo Orude & Another Vs Municipal Council of Kisumu [1971] EA 91
- Costa Construction Services Ltd v Globe Trotters Limited (High Court Civil Suit No. 790 of 2015)
- Uganda Development Bank Vs Muganga Construction Co. Ltd [1981] HCB 35
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.