Wakilii

Onang and 7 Others v Roofings Limited and Another (Civil Suit No. 139 of 2018)

High Court · [2022] UGHCCD 123 · 2022 Judgment for Defendant AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
First instance civil suit for alleged infringement of image rights and passing off
Decision
Suit dismissed with costs to the defendant and third party

Observed later treatment

Cited — treatment unverified cited in 1 (treatment unverified) Sequitur — Uganda’s citator · Derived from citing cases in the Wakilii corpus — not an assertion that this case is good law.

Citator coverage is limited to judgments in the Wakilii corpus and source-matched treatment records. Absence of a signal is not an assertion that the case remains good law.

No adverse treatment recorded Cited 1 time with no adverse treatment recorded; not yet tested on the merits. Derived from citing cases in the Wakilii corpus — a deterministic signal, not legal advice.

AI-generated summary. This summary was generated by AI from the full text of the judgment. It may contain errors or omissions—always read the source judgment before relying on it.

Holding

The court held that the plaintiffs, professional athletes who participated in a commercial video shoot for Roofings Limited's AZED iron sheets advertisement, gave implied consent to the use of their images. The court found that the plaintiffs were fully briefed on the purpose of the shoot, wore branded uniforms, were paid for their participation, and allowed filming without objection. The court distinguished the case from Asege Winnie v Opportunity Bank, holding that consent for commercial use of image rights need not be explicit or in writing where circumstances demonstrate implied consent. The suit was dismissed with costs.

Outcome

Suit dismissed with costs to the defendant and third party

Facts

On 19 August 2017, eight professional athletes from Prisons Athletics Club were approached by Moses Asonya, the National Athletics Coach, to participate in a sports activity. On 20 August 2017, they attended Namboole Stadium for what they claimed they believed was a sponsorship solicitation event. They were given sports uniforms bearing words including 'AZED', 'Feeke', 'Kiwani', and 'Kichups', and participated in a filmed race simulation with artificial rain effects created by water cannons. The filming was repeated multiple times. The plaintiffs were paid between 150,000 and 400,000 shillings. In December 2017, the plaintiffs discovered their images were used in a television commercial advertisement for Roofings Limited's AZED iron sheets. The defendant and third party contended that the plaintiffs were fully informed from the outset that the shoot was for a commercial advertisement, were briefed by the coach and production director, and were paid according to standard market rates for non-speaking roles in commercials.

Issues

  1. Whether the plaintiffs have a cause of action against the defendant and/or the third party?
  2. Whether the plaintiffs' image rights were infringed upon by the defendant and/or third party?
  3. Whether the defendant and/or third party are liable for passing off, misrepresentation, deceit and false endorsement?
  4. Whether the defendant and/or third party unjustly enriched themselves by use of the plaintiffs' images?
  5. Whether the plaintiffs are entitled to 10% royalty fees arising out of the sale of the product?
  6. Whether the third party is liable to indemnify the defendant for any sum the defendant may be adjudged to pay the plaintiffs?
  7. What remedies are available to the parties?

Orders

  • Suit dismissed.
  • Costs awarded to the defendant and third party.

Rules and key headnotes

Image Rights — Personality Rights — Elements of Infringement
Image rights refer to the use, appropriation and exploitation of a person's image, and include the expression of a personality in the public domain. To establish a prima facie case for violation of the right of publicity, the complaining party must prove: (1) validity — plaintiff owns an enforceable right in the identity of a human being; (2) infringement — (a) defendant, without permission, has used some aspect of identity or persona in such a way that plaintiff is identifiable from defendant's use, and (b) defendant's use is likely to cause damage to the commercial value of that persona.
Image Rights — Consent — Implied Consent Sufficient
Consent to the commercial use of a person's image need not be explicit or in writing. Implied consent may be inferred from a person's actions and the surrounding circumstances. Where a person participates in a commercial photo and video shoot, is briefed on its advertising purpose, wears branded uniforms, allows filming without objection, and accepts payment, implied consent to the use of their images may be found.
Image Rights — Distinction from Privacy Rights
The right of publicity is distinct from the right of privacy. Privacy rights are personal rights where damage is to human dignity and injury is measured primarily by mental distress. The right of publicity is a property right where damage is commercial injury to the business value of personal identity, and damages can include the fair market value of the plaintiff's identity, unjust enrichment, the infringer's profits, and damage to the business of licensing plaintiff's identity.
Passing Off — Image Rights — Consent as Defence
A sports figure or celebrity can complain when their name or likeness is used to advertise a product, but can recover damages only if they have not consented to such use or the advertising exceeds the consent granted. Where consent is established, claims for passing off, misrepresentation, and false endorsement fail.

Cases cited (6)

  • Asege Winnie v Opportunity Bank Ltd and MAAD Ltd (HCCS No. 756 of 2013)
  • Krouse v Chrysler Canada Ltd (1973) 13 CPR (2d) 28
  • Athans v Canadian Adventure Camps (1977) CAN H1 1255
  • Bassajabaka Yakub v MTN (U) Ltd (HCCS No. 100 of 2012)
  • Catherine Njeri Wanjiru v Machakos University (High Court Petition No. E021 of 2021)
  • Sharman v C Schmidt & Sons Inc 216 F Supp 401 (ED 1963)

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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The original judgment as reported. Read the original PDF before relying on any passage.

Onang and 7 Others v Roofings Limited and Another (Civil Suit No. 139 of 2018) [2022] UGHCCD 123 (22 August 2022)
Source: this page presents Wakilii’s issue analysis and metadata for a publicly reported Ugandan judgment. Any AI-generated summary is marked as such. Judgment text is sourced from the Uganda Legal Information Institute (ulii.org). Wakilii is not affiliated with ULII.