Digital Displays Ltd v Tim Construction Company Ltd & 3 Ors (CIVIL SUIT No. 021 OF 2015)
Observed later treatment
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Holding
A memorandum of understanding that fulfils all essential contractual elements is enforceable as a contract. The court pierced the corporate veil to hold a company director personally liable where he diverted partnership funds to an account where he was sole signatory, in breach of a single venture partnership agreement. The plaintiff was entitled to UGX 92,138,132 representing partnership funds wrongfully appropriated by the defendants, plus 20% interest from August 2014. The defendants' counterclaim was dismissed.
Outcome
Judgment entered for plaintiff; first and second defendants held jointly and severally liable; third defendant dismissed from suit
Facts
Digital Displays Limited (plaintiff) and TIM Construction Company Limited (first defendant) entered into a single venture partnership to rehabilitate Teladwong Primary School in Patiko sub-county for UGX 329,000,000. They executed memoranda of understanding in September 2012 and December 2013 governing financial management, sharing of proceeds, and duties. The plaintiff was to finance and execute the works, while the first defendant would obtain certificates and make joint bank withdrawals. The plaintiff claimed the defendants diverted partnership funds totaling UGX 105,000,000 to an account where the second defendant (managing director of first defendant) was sole signatory, in breach of their agreement that required joint signatures. The defendants counterclaimed that the plaintiff failed to inject promised capital and pay labourers, forcing the first defendant to rectify work and settle debts. The contract sum was UGX 597,942,450, later reduced to UGX 329,000,000 after sub-contracting. Six payment certificates were issued during execution. Evidence showed that labourers went on strike and the employer paid them directly. The second defendant received payments totaling UGX 139,506,532 through a Barclays Bank account, of which UGX 32,868,400 was paid to labourers, leaving UGX 106,638,132 unaccounted for.
Issues
- Whether the second defendant was a party to the contract.
- Whether the first and second defendant jointly or severally breached the contract.
- Whether the plaintiff is entitled to the sum of UGX 105,000,000.
- What remedies are available to the parties.
Orders
- Counterclaim dismissed.
- Judgment entered for the plaintiff against the first and second defendants jointly and severally for UGX 92,138,132.
- Interest at 20% per annum on UGX 92,138,132 from August 2014 until payment in full.
- Costs of the suit and of the counterclaim awarded to the plaintiff.
- Suit against third defendant dismissed with no order as to costs.
Rules and key headnotes
Legislation cited (8)
- Partnership Act 2 of 2010 s.2(1)
- Partnership Act 2 of 2010 s.3(d)(iv)
- Partnership Act 2 of 2010 s.21
- Partnership Act 2 of 2010 s.26
- Partnership Act 2 of 2010 s.26(a)
- Partnership Act 2 of 2010 s.34(1)(b)
- Partnership Act 2 of 2010 s.41(a)
- Civil Procedure Act s.26(1)
Cases cited (26)
- Dunlop Pneumatic Tyre Co Ltd v Selfridge Ltd [1915] AC 847
- Nanak Builders And Investors Pvt Ltd v Vinod Kumar Alag [1991] AIR 315
- Weddington Productions Inc v Flick (1998) 60 Cal.App.4th 793
- Salomon v A Salomon and Co Ltd [1897] AC 22
- Lennard's Carrying Co Ltd v Asiatic Petroleum Co Ltd [1915] AC 705
- Merchandise Transport Ltd v British Transport Commission [1962] 2 QB 173
- Trustor v Smallbone (No 2) [2001] WLR 1177
- DHN Food Distributors Ltd v Tower Hamlets London Borough Council [1976] 1 WLR 852
- Antonio Gramsci Shipping Corp v Stepanovs [2011] 1 Lloyd's Rep 647
- Fairline Shipping Corp v Adamson [1975] QB 180
- Royal Brunei Airlines SDN BHD v Tan [1995] 2 AC 378
- Body-Steffner Co v Flotill Products Inc 147 P.2d 84 (Cal. Ct. App. 1944)
- Steinke v Sungard Financial Systems Inc 121 F.3d 763 (1st Cir. 1997)
- Neville v Scott 127 A.2d 755 (Pa. Super. 1957)
- Marso v Mankato Clinic Ltd 278 Minn. 104 (1967)
- Investors Compensation Scheme Ltd v West Bromwich Building Society [1998] 1 WLR 896
- Henderson v Arthur [1907] 1 KB 10
- Jacob v Batavia and General Plantations Trust [1924] 1 Ch 287
- Muthuuri v National Industrial Credit Bank Ltd [2003] KLR 145
- Robin v Gervon Berger Association Limited [1986] WLR 526
- Sowah v Bank for Housing & Construction [1982-83] 2 GLR 1324
- Mohanlal Kakubhai Radia v Warid Telecom Ltd (High Court Civil Suit No. 234 of 2011)
- Kinyera v The Management Committee of Laroo Boarding Primary School (High Court Civil Suit No. 099 of 2013)
- Gilford v Horne [1933] Ch 935
- Jones v Lipman [1962] 1 WLR 832
- Ben Hashem v Ali Shayif [2009] 1 FLR 115
Cases citing this judgment (2)
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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