K-Solutions Limited v Attorney General (Civil Suit No. 122 of 2023)
Observed later treatment
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Holding
The High Court dismissed a procurement challenge brought as a tort claim, holding that the Public Procurement and Disposal of Public Assets Act 2021 establishes a mandatory statutory review mechanism through the PPDA Tribunal before appeal to the High Court on questions of law only. A plaintiff seeking to challenge a procurement decision must exhaust the statutory remedies or seek judicial review; circumventing these procedures by framing the dispute as a tort claim constitutes an abuse of process and renders the plaint incompetent.
Outcome
Suit dismissed on preliminary objection without determination on the merits
Facts
K-Solutions Limited participated in a tender process conducted by the Ministry of Water and Environment for hydro-metric equipment under Lots 1A and 1B. The plaintiff alleged it was not notified of the best evaluated bidder notice and only learned the contract had been awarded when it checked with the procurement department, by which time the statutory review period had expired. The plaintiff claimed the ministry selected another bidder despite the plaintiff being the lowest bidder, and that the ministry's actions were fraudulent and caused the plaintiff loss of bid preparation costs and expected income. The defendant contended that the best evaluated bidder notice was properly displayed, that the plaintiff failed to qualify on technical evaluation under Lot 1B and quoted a higher price under Lot 1A, and that the plaintiff failed to pursue available statutory remedies under the PPDA Act.
Issues
- Whether the suit is properly before court.
- Whether the plaint discloses a cause of action.
Orders
- Plaint dismissed as incompetent and wrongly before court.
- Costs awarded to the defendant.
Rules and key headnotes
Legislation cited (8)
- Public Procurement and Disposal of Public Assets Act 2021 s.91I
- Public Procurement and Disposal of Public Assets Act 2021 s.91L(4)
- Public Procurement and Disposal of Public Assets Act 2021 s.91M
- Public Procurement and Disposal of Public Assets Act 2021 s.89(7)
- Public Procurement and Disposal of Public Assets Act 2021 s.89(8)
- Public Procurement and Disposal of Public Assets Act 2021 s.89(9)
- Public Procurement and Disposal of Public Assets Act 2021 s.75
- Judicature (Judicial Review) Rules 2009 s.2
Cases cited (4)
- Smart Protus Magara and 138 Others v Financial Intelligence Authority (HCMA No. 215 of 2018)
- National Union of Clerical, Commercial & Technical Employees v NIC (SCCA No. 17 of 1993)
- Byaruhanga John Patrick v Commissioner Land Registration (HCMA No. 235 of 2024)
- O'Reilly v Mackman [1983] 2 AC 237
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
The original judgment as reported. Read the original PDF before relying on any passage.