Ceva Sante Animale v MTK Uganda Limited (Civil Suit No. 539 of 2021)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that a legally binding contract for the supply of veterinary products on credit was established from related commercial documents including proforma invoices, bills of lading, and invoices, read together with the defendant's conduct in accepting delivery and making partial payment. The distributor's obligation to pay for goods ordered and delivered is an independent contractual duty that is not discharged by subsequent revocation of a manufacturer's authorisation or the failure of an intended government supply arrangement, absent explicit contractual terms shifting such risk to the supplier. Judgment entered for the plaintiff for the outstanding debt of US $ 175,018.85 plus contractual interest at 10.11% per annum from the date of filing suit.
Outcome
Judgment entered for the plaintiff for the full amount claimed plus contractual interest and costs
Facts
The plaintiff, a French animal health company, entered into a verbal agreement in November 2018 to supply veterinary drugs and products on credit to the defendant, a Ugandan company dealing in health and agricultural products. The defendant placed orders and the plaintiff delivered goods invoiced at US $ 267,450.00 between November 2018 and April 2019. The defendant made partial payment of US $ 103,811.40 on 13th September 2019, leaving an outstanding balance of US $ 175,018.85. The defendant claimed the products were imported for supply to a government trypanosomiasis control project, but after the plaintiff established a separate company (Veribrand (U) Ltd) to conduct business directly in Uganda, the defendant's manufacturer's authorisation was revoked. The defendant sold some products on the open market for US $ 62,150 (which it remitted to the plaintiff) but claimed the rest expired. The defendant failed to file witness statements or present evidence at trial despite being represented by counsel.
Issues
- Whether the defendant is indebted to the plaintiff in the sum of US $ 175,018.85.
- What remedies are available to the parties?
Orders
- Judgment entered for the plaintiff against the defendant.
- A sum of US $ 175,018.85 awarded as the outstanding amount.
- Interest thereon at the contractual rate of 10.11% per annum from 27th August 2021 until payment in full.
- Costs of the suit awarded to the plaintiff.
Rules and key headnotes
Legislation cited (6)
- Contracts Act s.10(2)
- Contracts Act s.10(5)
- Contracts Act s.60(1)
- Civil Procedure Act s.26(2)
- Civil Procedure Act s.27(2)
- Civil Procedure Rules O.17 r.4
Cases cited (21)
- Protea Chemicals East Africa Limited v KAC Chemicals and Paints (U) Limited (Civil Suit No. 470 of 2016)
- Heis and others v. MF Global UK Services Ltd [2015] EWHC 883
- J.K. Patel v Spear Motors Ltd (Civil Appeal No. 4 of 1991)
- Borham-Carter v. Hyde Park Hotel [1948] 64 TLR
- Masaka Municipal Council v. Semogerere [1998-2000] HCB 23
- Musoke David v. Departed Asians Property Custodian Board [1990-1994] E.A. 219
- Translink Limited v Chemi & Cotex Industries Limited, Tanzania (CCIL) and two others (Civil Suit No. 100 of 2019)
- Carmichael v. Caledonian Railway Co. (1870) 8 M (HL) 119
- Mohanlal Kakubhai Radia v Warid Telecom Ltd (Civil Suit No. 234 of 2011)
- Kinyera v The Management Committee of Laroo Boarding Primary School (Civil Suit No. 099 of 2013)
- Storms v. Hutchinson [1905] AC 515
- Kabona Brothers Agencies v. Uganda Metal Products & Enamelling Co Ltd [1981-1982] HCB 74
- Kiwanuka Godfrey T/a Tasumi Auto Spares and Class mart v Arua District Local Government (Civil Suit No. 186 of 2006)
- Hungerfords v. Walker (1989) 171 CLR 125
- James Fredrick Nsubuga v Attorney General (Civil Suit No. 13 of 1993)
- Erukana Kuwe v Isaac Patrick Matovu and another (Civil Suit No. 177 of 2003)
- Hadley v. Baxendale (1894) 9 Exch 341
- Charles Acire v M. Engola (Civil Suit No. 143 of 1993)
- Kibimba Rice Ltd v Umar Salim (Civil Appeal No. 17 of 1992)
- Harriet Arinaitwe v Africana Clays Ltd (Civil Suit No. 376 of 2013)
- Spring Freight Logistics Limited v Amoo Holding International Limited and others (Civil Suit No. 556 of 2019)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.