Mengo Teachers Co-operative Savings And Credit Society Limited v The Registrar Of Co-operatives and Others (Miscellaneous Cause No. 49 of 2022)
Observed later treatment
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Holding
The High Court granted judicial review and declared that office bearers of a cooperative society who refused to hand over office to newly elected leaders after their term expired in December 2020, despite a special general meeting convened by the Registrar of Co-operatives on 4th September 2021 electing new officers, acted illegally and unlawfully. The court issued an injunction restraining the former office bearers from conducting business, mandamus compelling the Registrar to install the new leadership, and awarded punitive damages of UGX 50,000,000 each against the three respondents who refused to vacate office.
Outcome
Application granted; injunction and mandamus issued; former office bearers ordered to pay damages and costs
Facts
Mengo Teachers Co-operative Savings and Credit Society Limited was registered in 1965. The term of office of the chairperson and secretary expired in December 2020, but the 4th, 5th and 6th respondents (Dr Namugumya Esther, Ssenoga Charles, and Kibanga Christopher) continued to occupy office. In April 2021, they closed the society's offices and made complaints about financial mismanagement. The Registrar of Co-operatives convened meetings to resolve the governance impasse. On 12th August 2021, it was resolved that a special general meeting be held on 4th September 2021 to elect new leadership. The special general meeting was held on 4th September 2021 under the supervision of the Registrar. The 4th, 5th and 6th respondents did not attend. New office bearers were elected. Despite these elections, the 4th, 5th and 6th respondents refused to hand over office or surrender instruments of power. They sought police and security intervention claiming threatened violence and trespass. The applicant filed for judicial review in 2022 after the Registrar failed to resolve the matter internally and after receiving signed minutes on 24th January 2022.
Issues
- Whether there is justification for extension of time within which to file the application for judicial review?
- Whether the continued stay in office by the 4th, 5th and 6th respondents after the special general meeting of 4th September 2021 is illegal?
- Whether the applicant is entitled to the remedies sought?
Orders
- Extension of time to file the application for judicial review granted.
- Declaratory order issued that the continued holding of office by the 4th, 5th and 6th respondents after 4th September 2021 is illegal and unlawful.
- Injunction issued restraining the 4th, 5th and 6th respondents from conducting any business of the applicant and masquerading as office bearers.
- All business conducted by the 4th, 5th and 6th respondents after 4th September 2021 declared null and void.
- Order of Mandamus issued compelling the 1st respondent to put in effect the resolutions of the special general meeting of 4th September 2021, installing and protecting the new elected office bearers with immediate effect and not later than 7 days.
- The 4th, 5th and 6th respondents condemned to pay UGX 50,000,000 each as general and punitive damages to the applicant.
- Costs of the application awarded to the applicant.
Rules and key headnotes
Legislation cited (7)
- Constitution of Uganda Article 42
- Constitution of Uganda Article 44
- Constitution of Uganda Article 28
- Constitution of Uganda Article 50
- Judicature Act s.36
- Co-operative Society Act s.30
- Co-operative Society Act s.73
Cases cited (3)
- Kenya Revenue Authority v Menginya Salim Murgani (Civil Appeal No. 108 of 2009)
- R vs Aston University Senate ex p Roffey [1969] 2 QB 558
- R vs Secretary of State for Health ex p Furneaux [1994] 2 All ER 652
Cases citing this judgment (1)
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
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