Wakilii

Bunnya Erusa Namigadde v Bulime Cyrus and Another (Petition No. 41199 of 2024)

Tribunal · [2026] UGRSB 4 · 2026 Petition Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Petition before the Registrar of Companies alleging mismanagement of company affairs by respondent directors following death of majority shareholder
Decision
Petition dismissed on jurisdictional grounds due to pending High Court matter between the same parties

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The Registrar held that a member cannot acquire shares as a transferee using company funds, as the company is a separate legal entity from its members. The executed transfer forms were erroneous; the transaction should have been structured as a surrender of shares under Regulation 32(3) of the Companies Regulations. The Registrar dismissed the petition without costs, finding that the matter was precluded from hearing due to a pending High Court case between the same parties addressing substantially the same issues.

Outcome

Petition dismissed on jurisdictional grounds due to pending High Court matter between the same parties

Facts

The Petitioner, a director and shareholder holding 20 shares in Rakai Community School of Nursing Limited, filed a petition alleging that the Respondents (her stepchildren, also directors holding 10 and 5 shares respectively) mismanaged the company following the death of her husband, the majority shareholder and managing director. She alleged financial impropriety including unauthorized withdrawals, failure to remit examination fees, and refusal to cooperate in company operations. During alternative dispute resolution proceedings before the Registrar, the Respondents agreed to sell their shares and resign as directors. The company engaged Knight Frank Valuers, which valued the company at UGX 5.6 billion. The Petitioner paid the Respondents UGX 560 million and UGX 350 million respectively for their shares using company funds. The Respondents later challenged this arrangement, arguing that the Petitioner should have used personal funds. The Respondents refused to sign surrender deeds after receiving payment. Counsel for the Respondents subsequently notified the Registrar that a High Court matter (Miscellaneous Cause No. 361 of 2025) between the same parties was pending hearing.

Issues

  1. Whether the transfer of shares to the Petitioner, having paid for the said shares using company funds, could properly be said to be a transfer of shares to the Petitioner.
  2. Whether the Registrar of Companies can hear a matter that is pending determination before a Court of law.

Orders

  • Petition dismissed.
  • No order as to costs.

Rules and key headnotes

Company Law — Transfer of Shares — Use of Company Funds — Separate Legal Personality
A member of a company cannot acquire shares as a transferee utilizing company funds, as the company, being an artificial entity, is separate from the member. Transfer of shares is a commercial transaction pertaining to the rights of the transferor and transferee in personam.
Company Law — Shares — Surrender of Shares — Distinction from Transfer
Where a shareholder relinquishes shares to the company itself (rather than to another individual), the transaction should be structured as a surrender of shares pursuant to Regulation 32(3) of the Companies Regulations SI No. 74 of 2023, not as a transfer of shares. A surrender agreement must be registered with the Registrar, upon which the surrendered shares revert to the company.
Administrative Law — Registrar of Companies — Jurisdiction — Pending Court Proceedings
The Registrar of Companies shall not hear any matter pending before Court which has been brought to his or her notice. Civil proceedings are deemed to be before court when arrangements for hearing have been made, until the proceedings are ended by judgment, settlement or withdrawal.

Legislation cited (9)

Cases cited (1)

  • Barry Mpeirwe v Alsaco International Ltd (High Court Civil Suit No. 440 of 2014)

Full judgment

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

Bunnya Erusa Namigadde v Bulime Cyrus and Another (Petition No. 41199 of 2024) [2026] UGRSB 4 (4 February 2026)
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.