Mutebe v Joint Medical Stores (Labour Dispute Reference 132 of 2020)
Observed later treatment
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Holding
The Industrial Court held that the employer's non-renewal of the claimant's fixed-term contract was unlawful and unfair because the employer failed to follow its own Human Resources Policy Manual procedures. Although the claimant's redesignation to a new role did not create a new contract, the employer breached procedural requirements by failing to give three months' notice as required for employees with over ten years' service, failing to follow renewal timelines, and conducting an appraisal that suggested confirmation rather than non-renewal. The claimant was awarded three months' pay in lieu of notice, general damages, leave entitlement, and a certificate of service.
Outcome
Claimant's claim for unlawful termination granted; awarded payment in lieu of notice, general damages, leave entitlement, and certificate of service; claims for salary for remaining contract term and severance pay denied
Facts
The claimant was employed by the respondent in 2005 as a receiving officer and was promoted through various positions. In July 2017, his contract as Procurement Officer was renewed for two years, set to expire on 31 July 2019. On 23 January 2019, he was redesignated as Research and Development Officer. He accepted this redesignation on 1 February 2019 after receiving clarification on his new role. On 4 June 2019, he applied for contract renewal. On 20 June 2019, he received a performance appraisal rating of 80-95% with a recommendation for confirmation. On 17 July 2019, the respondent notified him that his contract would expire on 31 July 2019 and would not be renewed. The claimant received this letter on 31 July 2019. He was paid his terminal benefits but not given three months' notice or payment in lieu thereof. The claimant had served for 14 years.
Issues
- Whether the Respondent unlawfully and unfairly terminated the Claimant's employment?
- Whether the Claimant's redesignation from Procurement Officer to Research and Development Officer amounted to a new contract?
- What remedies are available to the parties?
Orders
- It is declared that the Claimant was unlawfully and unfairly terminated from employment by the Respondent.
- The Respondent is directed to issue a certificate of service within 15 days from the date of this award.
- The Respondent is directed to compute and pay the Claimant his leave entitlement from January to July 2019 and report to the Registrar within 45 days.
- The Respondent is ordered to pay the Claimant UGX 13,230,000 as payment in lieu of notice.
- The Respondent is ordered to pay the Claimant UGX 4,400,000 in general damages.
- There is to be no order as to costs.
Rules and key headnotes
Legislation cited (9)
- Employment Act Cap. 226 s.2
- Employment Act Cap. 226 s.26
- Employment Act Cap. 226 s.57(3)(d)
- Employment Act Cap. 226 s.60
- Employment Act Cap. 226 s.64(1)(b)
- Employment Act Cap. 226 s.64(2)(b)
- Employment Act Cap. 226 s.65(1)
- Employment Act Cap. 226 s.86
- Labour Disputes (Arbitration and Settlement) Act Cap. 227 s.8(3)(d)
Cases cited (24)
- Mbonyi Julius v Appliance World Limited ([2021] UGIC 10)
- Hilda Musinguzi v Stanbic Bank, Uganda Limited (SCCA 05 of 2016)
- Ojok and 87 Others v Torres Advanced Enterprises Solutions LLC
- Akewa v Loving One by One Ministries
- Elizabeth Nabatanzi Lugudde Katwe v Attorney General (CACA 53 of 2017)
- Greenboat Entertainment Ltd v City Council of Kampala ([2007] UGCommC 21)
- Dixon v BBC [1979] QB 546
- British Broadcasting Corporation v. loannou (1975) 1 QB 781
- Kiwalabye & Ors v Posta Uganda ([2019] UGIC 23)
- Tibenkana v London Distillers (U) Limited
- Albert Tinto v Smart Communication Inc (G.R. No. 171764)
- Blue Dairy Corporation v National Labour Relations Commission (G.R No. 129843, September 14 1999)
- Lubega v Tropical Bank Limited ([2024] UGIC 39)
- Mt. Elgon Hospital v Nangosya ([2020] UGIC 18)
- Transparency International - Kenya v Omondi [2023] KECA 174 (KLR)
- Francis Chire Chachi v Amatsi Water Services Company Limited [2012] eKLR
- Registered Trustees of the Presbyterian Church of East Africa & another v Ruth Gathoni Ngotho-Kariuki [2017] eKLR
- Tindyebwa and Another v Kabale University
- Kamuli v DFCU Bank ([2015] UGIC 10)
- Eqimu v Henly Distributors Uganda Limited ([2024] UGIC 52)
- Uganda Post Limited v Mukadisi ([2023] UGSC 58)
- Stanbic Bank (U) Limited v Okou ([2023] UGCA 100)
- Sserunjogi v Guinness Transporters Limited Ta Safe Boda
- Kalule v Deustche Gesellschaft Fuer Internationale Zuzammenarbeit (GIZ) GMBH ([2023] UGIC 89)
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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