Bateisibwa v Lake Victoria Authorities & Anor (Labour Dispute Claim 192 of 2014)
Observed later treatment
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Holding
The Industrial Court dismissed a claim for salary arrears where the employment contract expressly provided that the employee's salary would be funded from sources the employee himself was to mobilize. The claimant failed to prove that funds he claimed to have mobilized were actually received by the respondent employer. The court held that the employer's obligation to pay wages under the Employment Act only arose after proof that the respondent received funding as a result of the claimant's mobilization efforts.
Outcome
Claim for salary arrears dismissed
Facts
The claimant was engaged as Secretary General by the respondent under a contract dated 1 September 2011 for one year at USD 4,000 per month. The contract provided that salary from April to August 2012 would be met from chapter contributions or any other source identified by the claimant. The claimant was paid up to 31 March 2012 from a Sida agreement. In mid-August 2013, the claimant informed the respondent of his intention to resign due to non-payment of salary for the period April 2012 to August 2013. The respondent immediately asked him to vacate office. The claimant claimed he mobilized £85,500 and Euros 10,000 to cover project costs but was not paid his salary. He filed a claim for USD 72,000 in salary arrears.
Issues
- Whether the respondent breached the employment contract by failing to pay the claimant's arrears?
- What are the remedies available to parties?
Orders
- Claim dismissed.
- No orders as to costs.
Rules and key headnotes
Legislation cited (3)
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.