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Base Electronic Centre v Energo Project (Civil Suit No. 697 of 1990)

High Court · [1992] UGHC 23 · 1992 Judgment for Defendant AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
First instance civil suit for payment on quantum meruit basis
Decision
Plaintiff's claim dismissed; amount already paid by defendant held to be reasonable remuneration

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

Where services are rendered at the defendant's request without prior agreement on price, payment must be on a quantum meruit basis at a reasonable rate. The court rejected the plaintiff's claim for 30% of estimated equipment cost as highly inflated and held that the sum already paid by the defendant represented reasonable remuneration considering the services rendered and the defendant's substantial assistance with civil works, transport, and accommodation.

Outcome

Plaintiff's claim dismissed; amount already paid by defendant held to be reasonable remuneration

Facts

In June 1990, the plaintiff, a registered electronics firm, installed a satellite disc at the defendant's camp in Kiganda to enable the defendant's Yugoslav staff to view the World Cup. No price was agreed before installation. The plaintiff later submitted a bill for UGX 2,640,000, then reduced it to UGX 1,518,000 after negotiations. The defendant rejected both bills as excessive and paid UGX 450,000 as reasonable remuneration. The plaintiff accepted payment without prejudice and sued for the balance, claiming UGX 1,992,000 after adjusting for returned equipment. The defendant provided transport, accommodation, food, and performed all civil engineering works including ground leveling, stand fabrication, concrete foundation, and crane service. The plaintiff's professional work included detecting the satellite belt, aligning the disc, and commissioning the system. The plaintiff claimed his fee should be 30% of the equipment's CIF cost but admitted he did not know the actual CIF cost and used a rough estimate.

Issues

  1. What is the reasonable amount for the work done on a quantum meruit basis where services were rendered without prior agreement on price?

Orders

  • Claim dismissed.
  • Costs awarded to the defendant.

Rules and key headnotes

Contract Law — Quantum Meruit — Implication of Reasonable Payment
Where services have been rendered by the plaintiff or goods supplied at the request of the defendant without prior agreement on price, it is implied that the defendant is required to pay a reasonable price for the services rendered or goods supplied.
Contract Law — Quantum Meruit — Assessment of Reasonable Remuneration
In assessing reasonable remuneration on a quantum meruit basis, the court must consider not only the services rendered by the plaintiff but also any assistance provided by the defendant, including provision of materials, labour, equipment, transport, and accommodation.
Contract Law — Professional Fees — Burden of Proof
A plaintiff claiming professional fees based on an alleged standard charging method bears the burden of establishing by satisfactory evidence that such method is indeed a recognised standard in the profession, and must further establish the accurate basis for calculation where the method depends on equipment cost or other measurable factors.

Legislation cited (1)

  • Registration Of Business Names Act

Cases cited (1)

  • Moses V S C Ferlan 1760

Full judgment

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

Base Electronic Centre v Energo Project (Civil Suit No. 697 of 1990) [1992] UGHC 23 (14 August 1992)
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.