Bank of Uganda v Masaba & 5 Others (Civil Appeal 3 of 1998)
Observed later treatment
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Holding
The Supreme Court dismissed Bank of Uganda's appeal. The Governor's letter offering a voluntary retirement scheme, which represented that housing loans would not be deducted from retirement packages, was a binding offer accepted by the respondents who retired in reliance on it; deducting the loans breached that contract. The representation was also a negligent misrepresentation under Hedley Byrne, the Bank owing its employees a duty of care to ensure it was accurate. Misrepresentation had been sufficiently pleaded under Order 6 rule 2 when the paragraphs were read together. Applying Esso Petroleum v Mardon and Hadley v Baxendale, the trial courts' awards of general damages and refund of the deducted loans were properly made and were upheld.
Outcome
Appeal dismissed with costs; the trial courts' awards of general damages and the orders for refund of the deducted housing loans affirmed.
Facts
Bank of Uganda, facing financial difficulties, sought to reduce its workforce. Its Governor's letter of 1 November 1994 offered employees a voluntary retirement scheme with a compensation package, representing in clause 5 that housing loans would not be deducted but would be registered as legal mortgages repaid over a period to be agreed before departure. The respondents, long-serving employees whose housing loans were secured by land certificates held by the Bank, applied to retire in reliance on that representation. When paid, they found their housing loans deducted from their packages, leaving them with little. Later circulars of December 1994 and January 1995 reversed the earlier representation, attributing the deductions to a Ministry of Finance ruling. The respondents sued: the first respondent in Civil Suit No. 633 of 1995 and the other five in Civil Suit No. 725 of 1995. The trial courts found false representation and breach of contract, awarding general damages and ordering refund of the deducted loans. The Court of Appeal dismissed the Bank's consolidated appeals.
Issues
- Whether negligent misrepresentation was properly pleaded under Order 6 rule 2 of the Civil Procedure Rules and proved against the appellant.
- Whether the principle of negligent misrepresentation was applicable to the facts of the case.
- Whether the appellant's circular of 1 November 1994 constituted a binding offer or merely an invitation to treat.
- Whether a binding contract existed under which the respondents' housing loans would not be deducted from their voluntary retirement packages.
- Whether the appellant could be ordered to refund the deducted housing loans absent a provision for their repayment.
- Whether the trial judges properly directed themselves on the quantum of damages.
Orders
- Appeal dismissed.
- Costs of the appeal awarded to the respondents, both in this court and in the court below.
Rules and key headnotes
Legislation cited (4)
- Civil Procedure Rules Order 6 rule 2
- Rules of the Supreme Court rule 93
- Evidence Act s.113
- Civil Procedure Act s.101
Cases cited (20)
- Stephen Lubega v Barclays Bank (Civil Appeal No. 2 of 1992)
- Okello Okello v Uganda National Examinations Board (Civil Appeal No. 12 of 1998)
- Interfreight (U) Ltd v East African Development Bank (Civil Appeal No. 3 of 1993)
- Hedley Byrne & Co Ltd v Heller & Partners Ltd [1964] AC 465
- Edwards v Skyways Ltd [1964] 1 WLR 349
- Esso Petroleum Co Ltd v Mardon [1976] 2 All ER 5
- Mutual Life & Citizens' Assurance Co Ltd v Evatt [1971] 1 All ER 150
- Candler v Crane Christmas & Co [1951] 1 All ER 426
- Hughes v Metropolitan Railway Co (1877) 2 App Cas 439
- Central London Property Trust Ltd v High Trees House Ltd [1947] KB 130
- Everden vs. Guildford City Association Football Club Ltd. (1975) 3 All ER
- Nurdin Bandali v Lombank Tanganyika Ltd [1963] EA 304
- Century Automobiles v Hutchings Biemer Ltd [1965] EA 304
- May & Butcher Ltd v R [1934] 2 KB 17
- Hadley v Baxendale (1854) 156 ER 145
- Victoria Laundry (Windsor) Ltd v Newman Industries Ltd [1949] 1 All ER 997
- V R Chande v East African Airways Corporation [1964] EA 5
- Cook vs. Spanish Holiday Tours (London) Ltd. (1960) "Times" 6 February
- Flint v Lovell [1935] 1 KB 354
- Doyle v Olby (Ironmongers) Ltd [1969] 2 All ER 119
Cases citing this judgment (4)
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
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