Finance & Allied Workers Union v Bank of Baroda (U) Limited (Miscellaneous Cause 255 of 2022)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The High Court lacks jurisdiction to entertain an application concerning union recognition and collective bargaining where the Labour Unions Act provides a specific statutory remedy through the Industrial Court. Section 23(6) of the Labour Unions Act directs aggrieved parties to refer disputes to the Industrial Court where the Registrar declines to make an order. The Industrial Court has concurrent jurisdiction with the High Court but is the appropriate forum for statutory labour union disputes. Fundamental rights enforcement procedures cannot be used to circumvent specific statutory remedies provided in labour legislation.
Outcome
Application struck out for lack of jurisdiction and dismissed with costs to the respondent
Facts
The applicant union sought orders compelling the respondent bank to recognize it, sign a recognition agreement, and commence collective bargaining, alleging the bank refused recognition based on an existing agreement with another union. The applicant claimed the bank's employees who were its members were being forced to join a different union. The applicant complained to the Registrar of Labour Unions who allegedly ignored the complaint. Rather than referring the matter to the Industrial Court as provided under section 24(6) of the Labour Unions Act, the applicant filed a miscellaneous cause in the High Court Civil Division under constitutional provisions and the Judicature (Fundamental and Other Human Rights and Freedoms) (Enforcement Procedure) Rules.
Issues
- Whether the High Court has jurisdiction to entertain the applicant's complaint concerning union recognition and collective bargaining rights.
- Whether it is lawful for the respondent to refuse to recognize the applicant union and sign a recognition agreement on account of an existing recognition agreement with another union.
- Whether the respondent's refusal to recognize the applicant union on account of the National Tripartite Charter on Labour Relations infringed the rights of the applicant's members.
- Whether the applicant is entitled to the reliefs sought.
Orders
- Application dismissed.
- Costs awarded to the respondent.
Rules and key headnotes
Legislation cited (18)
- Constitution of Uganda Article 29(1)(c)
- Constitution of Uganda Article 40(3)
- Constitution of Uganda Article 50(1)
- Constitution of Uganda Article 50(2)
- Constitution of Uganda Article 129(1)(c)
- Constitution of Uganda Article 129(1)(d)
- Constitution of Uganda Article 139(1)
- Labour Unions Act s.3
- Labour Unions Act s.4
- Labour Unions Act s.5
- Labour Unions Act s.23(6)
- Labour Unions Act s.24(1)(d)
- Labour Unions Act s.24(2)
- Labour Unions Act s.24(3)
- Labour Unions Act s.24(6)
- Judicature (Fundamental and Other Human Rights and Freedoms) (Enforcement Procedure) Rules s.2
- Employment Act 2006 s.93(1)
- Employment Act 2006 s.94
Cases cited (5)
- Ozuu Brothers Enterprises v Ayikoru (High Court Civil Revision No. 2 of 2016)
- 201 Former Employees of G4S Security Services (U) Limited v G4S Security Services (U) Limited (Supreme Court Civil Appeal No. 180 of 2010)
- Ruhinda Asaph Ntegye and Another v Attorney General (Constitutional Petition No. 33 of 2016)
- Uganda Railways Corporation v Ekwaru and 133 Others (Civil Appeal No. 7 of 2019)
- Uganda Revenue Authority v Rabbo Enterprises Limited and Another (Civil Appeal No. 12 of 2004)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.