Najjuma Prossy Kwagala and Another v Kabira Country Club (Labour Dispute Reference No. 157 of 2019)
Observed later treatment
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Holding
The Industrial Court held that the Respondent's attempt to impose new written employment contracts with adverse terms on employees who had served under oral contracts for 3 to 18 years, without proper consultation or consent, constituted a repudiation of the existing contracts and amounted to constructive dismissal. The termination was both procedurally and substantively unlawful. The Court awarded the 41 Claimants unpaid wages for January 2019, severance allowance computed at one month's salary per year served, notice pay, general damages of UGX 5,000,000 each, and repatriation for those who served 10 years or more, with interest.
Outcome
Claimants' claims for unlawful termination allowed; awarded unpaid wages, severance allowance, notice pay, general damages, and repatriation for qualifying employees; claims for overtime, public holiday pay, and accrued leave dismissed for lack of proof
Facts
The 41 Claimants were employed by Kabira Country Club under oral contracts for periods ranging from 3 to 18 years in various positions including supervisors, cleaners, waiters, and attendants, earning monthly salaries between UGX 230,000 and UGX 470,000. Some were members of the Uganda Hotels, Food, Tourism, Supermarkets and Allied Workers' Union, which had a Collective Bargaining Agreement with the Respondent from April 2017. In December 2018, the Respondent attempted to convert oral contracts to written one-year contracts with adverse terms including probation clauses, reduced salaries, and shortened contract durations. On 14 January 2019, the Claimants were denied access to the workplace and informed via a notice at the gate that they were no longer employees after they refused to sign the new contracts. They had worked 11 days in January 2019 without payment. The Claimants reported the dispute to the Ministry of Gender, Labour and Social Development on 4 February 2019, which referred it to the Industrial Court.
Issues
- Whether the Claimants were unlawfully and unfairly terminated by the Respondent?
- Whether the Collective Bargaining Agreement (CBA) applied to the Claimants and, if so, whether the terminal dues should be computed in accordance with it?
- Whether the Claimants are entitled to benefits in form of overtime pay, public holidays, or repatriation at the cost of the Respondent?
- What other remedies are available to the parties?
Orders
- The Claimants were unlawfully constructively dismissed by the Respondent.
- The Claimants are awarded UGX 4,258,859 as unpaid wages for 11 days worked in January 2019.
- The Claimants are awarded UGX 122,460,956 as severance allowance.
- The Claimants are awarded UGX 27,658,819 as notice pay.
- The Claimants are awarded UGX 205,000,000 as general damages.
- The monetary awards save for general damages shall carry interest of 12% per annum from the date of filing in the Industrial Court until payment in full.
- General damages shall carry interest of 18% per annum from the date of this award until payment in full.
- No order as to costs is made.
Rules and key headnotes
Legislation cited (12)
- Employment Act 2006 s.2
- Employment Act 2006 s.22
- Employment Act 2006 s.38
- Employment Act 2006 s.39
- Employment Act 2006 s.40
- Employment Act 2006 s.42
- Employment Act 2006 s.52
- Employment Act 2006 s.53
- Employment Act 2006 s.57
- Employment Act 2006 s.86
- Employment Act 2006 s.87
- Constitution of the Republic of Uganda 1995 Article 126(2)(c)
Cases cited (11)
- Wells v Newfoundland [1999] 3 SCR 199
- Universe Tankships v ITWF [1981] ICR IRLR 239
- Mears v Safecar Ltd [1983] QB 54
- Symon Wairobi Gatuma v Kenya Breweries Ltd (Petition No. E023 of 2023)
- African Field Epidemiology Network (AFENET) v Kityaba (Civil Appeal No. 124 of 2017)
- Donna Kamuli v DFCU Bank Limited (LDC No. 02 of 2015)
- Framptons Ltd v Badger (EAT 138/06)
- Mbiika v Centinary Bank Ltd (LDC No. 23 of 2014)
- Florence Mufumba v Uganda Development Bank Ltd (Labour Dispute Claim No. 138 of 2014)
- Dr. Peter Waswa Kityaba v African Field Epidemiology Network (AFENET) (Labour Dispute Reference No. 84 of 2016)
- Post Bank Uganda vs Florence Mukadisi
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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