Goldstar Insurance Company Limited v Bank of Uganda [2025] UGPPDPAAT 28
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The Tribunal held that the application was time-barred and struck it out. The Accounting Officer's administrative review decision dated 29 July 2025 was made outside the statutory ten-day period prescribed by section 106(7) of the Public Procurement and Disposal of Public Assets Act and was therefore null and void. The applicant's challenge, filed on 8 August 2025, was one day late under section 115(2)(c), which requires applications to be filed within ten days from the date of expiry of the period specified in section 106(7). The Tribunal held that limitation statutes are strict and inflexible, and non-compliance renders the application incompetent regardless of merits.
Outcome
Application struck out as time-barred
Facts
Bank of Uganda initiated a restricted bidding procurement for workers' compensation insurance cover on 15 May 2025, inviting 20 non-life insurance firms. Seven bidders submitted proposals by 2 June 2025. On 4 July 2025, Bank of Uganda issued a Notice of Best Evaluated Bidder declaring Sanlam General Insurance Uganda Limited the winner with a contract price of UGX 3,198,406,022. Goldstar Insurance Company Limited (the applicant) was ranked second with a weighted average score of 66%. The applicant sought clarification on 7 July 2025 and filed an administrative review complaint on 16 July 2025, alleging that the best evaluated bidder contravened insurance pricing regulations. The Accounting Officer issued a decision on 29 July 2025 upholding the award. The applicant filed an application before the Tribunal on 8 August 2025 challenging the procurement decision.
Issues
- Whether the instant Application is time barred?
- Whether the Application is incompetent due to failure to give notice to the Respondent's Accounting Officer?
- Whether the Respondent acted unlawfully by introducing new grounds for eliminating the Applicant's proposal during the review of the Applicant's complaint?
- Whether the Applicant's proposal covered pregnant staff?
- Whether the Best Evaluated Bidder's proposal contravened the Insurance (Minimum Premium and Maximum Commission Rates) Regulations 2023 by offering a higher benefit for the child and pregnancy policy extension exceeding UGX 2,000,000 without charging an additional premium?
- Whether the Applicant's bid was non-compliant with the Insurance (Minimum Premium and Maximum Commission Rates) Regulations 2023, specifically regarding the coverage of pregnant staff, the proposed premium rate of UGX 3,198,406,014, and the quotation of benefits exceeding the maximum per-staff limits for funeral and medical expenses as stipulated in Schedule 1 of the Regulations?
- What remedies are available to the parties?
Orders
- The Application is struck out.
- The Tribunal's suspension order dated August 8, 2025, is vacated.
- Each party shall bear its own costs.
Rules and key headnotes
Legislation cited (10)
- Public Procurement and Disposal of Public Assets Act Cap 205 s.106(7)
- Public Procurement and Disposal of Public Assets Act Cap 205 s.106(8)
- Public Procurement and Disposal of Public Assets Act Cap 205 s.106(10)
- Public Procurement and Disposal of Public Assets Act Cap 205 s.115(2)(c)
- Public Procurement and Disposal of Public Assets (Contracts) Regulations 2023 reg.3(l)(d)
- Public Procurement and Disposal of Public Assets (Administrative Review) Regulations 2023 reg.8
- Public Procurement and Disposal of Public Assets (Administrative Review) Regulations 2023 reg.9(2)
- Interpretation Act Cap 6 s.34(1)(b)
- Insurance (Minimum and Maximum Commission Rates) Regulations 2023
- Workers' Compensation Act
Cases cited (8)
- Frida B. Kwikiriza v Buliisa District Local Government (Application No. 28 of 2022)
- Gold Star Insurance Company Limited v Uganda National Oil Company (Application No. 18 of 2025)
- BUU-Lepu Foundation Ltd v Lira City Council (Application No. 14 of 2025)
- Maclhvani International SA v Attorney General (SCCA No. 23 of 2010)
- Hilton v Sutton Steam Laundry [1956] 1 KB 73
- Eclipse Edisoil JVC Ltd v Napak District Local Government (High Court Civil Appeal No. 05 of 2024)
- Goldstar Insurance Company Ltd v National Medical Stores (Application No. 014 of 2021)
- Allpay Consolidated Investment Holdings (Pty) Ltd & Ors vs CEO of the South African Social Security Agency
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.