Kyagulanyi Ssentamu v The Commissioner General Uganda Revenue Authority (H.C.Miscellaneous Application No. 150 of 2021)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that the High Court has jurisdiction to hear the application for temporary injunction notwithstanding it concerns a tax matter, as the purpose of a temporary injunction is to maintain the status quo and the issue of jurisdiction will be determined in the main suit. Held further that the applicant failed to demonstrate that he would suffer irreparable injury from the temporary recall of his motor vehicle for re-examination by URA. Application dismissed.
Outcome
Application for temporary injunction dismissed
Facts
The applicant Kyagulanyi Ssentamu Robert filed a civil suit challenging URA's decision to recall his motor vehicle registration number UBF 667 F (Toyota Land Cruiser V8) for re-examination. The vehicle had been assessed, cleared and registered by URA on 12 January 2021. URA later made preliminary findings and by letter dated 24 February 2021 requested the applicant to voluntarily present the vehicle for re-verification. The applicant refused and sought a temporary injunction restraining URA from enforcing the recall or impounding the vehicle pending determination of the main suit. The applicant claimed he used the vehicle as his main means of transport and for personal security. URA opposed the application arguing it had statutory powers under the East African Community Customs Management Act 2004 to recall and re-examine goods already cleared.
Issues
- Whether the High Court has jurisdiction to entertain an application for a temporary injunction in a matter concerning a taxation decision by the Commissioner of Customs.
- Whether the case is a proper one to grant a temporary injunction.
Orders
- Application dismissed.
- No order as to costs.
Rules and key headnotes
Legislation cited (6)
- Judicature Act s.38
- Civil Procedure Rules Order 41 r.2(1)
- Civil Procedure Rules Order 41 r.2(2)
- Civil Procedure Rules Order 41 r.9
- East African Community Customs Management Act 2004
- Tax Appeals Tribunal Act
Cases cited (5)
- Shiv Construction v Endesha Enterprises Ltd (Civil Appeal No. 34 of 1992)
- E.L.T Kiyimba Kaggwa v Haji Abdu Nasser Katende [1985] HCB 43
- R v Secretary of State for Transport ex.p Factortame Ltd [1990] 2 AC 85
- Daniel Mukwaya v Administrator General (H.C.C.S. No. 630 of 1993)
- Erisa Rainbow Musoke v Ahamada Kezala [1987] HCB 81
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.