IN RE British American Tobacco (Uganda) Limited (MISCELLANEOUS CAUSE NO. 107 0F 2020)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that where COVID-19 restrictions on public gatherings made it impracticable for a public company with approximately 1,230 members to convene an Annual General Meeting in the manner prescribed by its Articles of Association, the court under section 142 of the Companies Act 2012 has power to order that the meeting be held by electronic means to ensure compliance with statutory requirements and enable the company to operate smoothly.
Outcome
Application granted with conditions
Facts
British American Tobacco Uganda Limited is a public company listed on the Uganda Securities Exchange with approximately 1,230 members both local and foreign. The company is required by its Articles of Association, the Companies Act 2012, and listing rules to convene an Annual General Meeting for the year ended 31st December 2019. The Articles require physical attendance with a quorum of at least 7 members present in person. Following the COVID-19 pandemic declaration by WHO on 11th March 2020 and notification as a health emergency in Uganda on 17th March 2020, the Government implemented public health measures including a blanket ban on public meetings under the Public Health (Control of COVID-19) Rules 2020. The statutory requirement mandates holding the AGM within 15 months of the last meeting, requiring the meeting to occur by 22nd August 2020. Fred Tumwesigye Bisamunyu, a director and member of the company, applied to court seeking leave to hold the AGM by electronic means.
Issues
- Whether the court should grant leave to British American Tobacco Uganda Limited to convene and conduct its Annual General Meeting by electronic means due to COVID-19 restrictions on public gatherings.
Orders
- British American Tobacco Uganda Limited is granted leave to convene and conduct the Annual General Meeting for the year ended 31st December 2019 by electronic means.
- The leave is subject to obtaining a prior no-objection from Uganda Securities Exchange and complying with all applicable notices issued under the Uganda Securities Exchange Listing Rules 2003 and the law.
- The costs of this application are to be met by the company.
Rules and key headnotes
Legislation cited (5)
- Companies Act 2012 s.142
- Judicature Act s.33
- Civil Procedure Rules Order 38 r.6(h)
- Uganda Securities Exchange Listing Rules 2003
- Public Health (Control of COVID-19) Rules 2020
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.