Edotun v Okra Beverages Limited (Labour Dispute Reference 261 of 2021)
Observed later treatment
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Holding
The Industrial Court held that the claimant was constructively dismissed when the employer asked him to leave work pending resumption of operations, but the next day replaced him with another employee and recalled all other workers. The employer's conduct constituted unreasonable conduct under Employment Act s.65(1)(c), amounting to constructive dismissal. The claimant was awarded salary arrears, severance pay, payment in lieu of notice, and general damages. The claim for unpaid leave was denied for lack of evidence that leave was applied for and denied.
Outcome
Claimant's claim for constructive dismissal granted; awarded salary arrears, severance pay, payment in lieu of notice, and general damages; claim for unpaid leave denied
Facts
The claimant was employed as General Manager of the respondent company from May 2015 at a monthly salary of UGX 1,000,000. On 28 August 2021, the respondent's Managing Director convened a meeting and directed the claimant to hand over office keys and equipment, asking him to go home and wait for a call when conditions improved. The director gave the claimant UGX 2,000,000 and told him to await contact. When the claimant returned to work the next day, he found his office occupied by Wilson Magambo and all other workers back on duty. His subsequent calls to the company went unanswered. He lodged a complaint with the Mpigi District Labour Office on 20 September 2021, which referred the matter to the Industrial Court. The respondent did not attend court hearings and its advocates withdrew. The court granted leave to proceed ex parte.
Issues
- Whether the Claimant was unfairly terminated from employment by the Respondent?
- What remedies are available to the parties?
Orders
- Declaration that the Claimant was unfairly terminated from the Respondent's service.
- Respondent to pay UGX 2,000,000 as payment in lieu of notice.
- Respondent to pay UGX 7,294,443 as severance pay.
- Respondent to pay UGX 1,000,000 as salary arrears for August 2021.
- Respondent to pay UGX 12,000,000 as general damages.
- All sums to carry interest at 18% per annum from the date of the award until payment in full.
- Respondent to issue a certificate of service within 21 days from the date of the award.
- No order as to costs.
Rules and key headnotes
Legislation cited (15)
- Employment Act 2006 s.40
- Employment Act 2006 s.40(6)
- Employment Act 2006 s.58(1)(c)
- Employment Act 2006 s.61
- Employment Act 2006 s.65
- Employment Act 2006 s.65(1)(a)-(c)
- Employment Act 2006 s.65(1)(c)
- Employment Act 2006 s.66
- Employment Act 2006 s.68
- Employment Act 2006 s.69
- Employment Act 2006 s.69(3)
- Employment Act 2006 s.70(6)
- Employment Act 2006 s.81
- Employment Act 2006 s.87
- Civil Procedure Rules S.I. 71-1 Order 9 Rule 20(1)(a)
Cases cited (21)
- Hilda Musinguzi v Stanbic Bank (U) Ltd (Supreme Court Civil Appeal No. 05 of 2016)
- Kasenge Geoffrey Oscar v St Augustine Montessori School (Labour Dispute Reference No. 207 of 2017)
- Eva Nazziwa Lubowa v NSSF (Labour Dispute Reference No. 001 of 2019)
- Geoffrey Brown v Ojijo Pascal (High Court Civil Suit No. 228 of 2017)
- Uganda Revenue Authority v Stephen Mabosi (Supreme Court Civil Appeal No. 26 of 1995)
- George Wimpey Ltd v Cooper [1977] IRLR 205
- Nyakabwa J. Abwoli v Security 2000 Ltd (Labour Dispute Claim No. 108 of 2014)
- Moses Kiplagat Changwony v Tana and Athi Rivers Development Authority Industrial Cause No.785 of 2010 [2010] UR 175
- Okumu and Others v Shreeji Stationers (Labour Dispute Reference No. 138 of 2021)
- Edace Michael v Watoto Child Care Ministries (Labour Dispute Appeal No. 21 of 2015)
- African Field Epidemiology Network v Peter Waswa Kityaba (Civil Appeal No. 124 of 2017)
- Re Loty and Holloway v Australian Workers' Union [1971] AR (NSW) 95
- Simon Kapio v Centenary Bank (Labour Dispute Claim No. 300 of 2015)
- Equity Bank v Musimenta Rogers (Labour Dispute Appeal No. 26 of 2007)
- Blanche Byarugaba Kaira v AFNET (Labour Dispute Reference No. 131 of 2018)
- Chandia Christopher v Abacus Pharma (AFRICARE) Ltd (Labour Dispute Reference No. 237 of 2016)
- Donna Kamuli v DFCU Ltd (Labour Dispute Claim No. 002 of 2015)
- Stroms v Hutchinson [1950] A.C 515
- Stanbic Bank (U) Ltd v Constant Okou (Civil Appeal No. 60 of 2020)
- Kibimba Rice Limited v Umar Salim (Supreme Court Civil Appeal No. 17 of 1992)
- Joseph Kalule v GIZ (Labour Dispute Reference No. 109 of 2020)
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.