Peter Katongole v Airtel Uganda Limited (Labour Dispute Reference No. 188 of 2022)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The Industrial Court held that a claimant unlawfully dismissed from employment is entitled to general damages for non-pecuniary harm such as emotional distress and inconvenience, in addition to statutory compensation for unfair dismissal. Aggravated damages require proof of malice, callousness or deliberate humiliation by the employer. General damages awarded were UGX 31,030,000 (equivalent to three months' gross salary), reflecting the claimant's mitigation of loss through re-employment. Aggravated damages denied due to absence of employer misconduct. No costs awarded, as costs in employment disputes are exceptional.
Outcome
Claimant awarded general damages for unlawful dismissal; aggravated damages and costs denied
Facts
The Claimant, a Revenue Assurance and Fraud Manager, was employed by the Respondent telecommunications company for thirteen years. In October 2020, he was dismissed following allegations that he failed to report and act on commission fraud flagged by the Respondent's India team, and that he generated a parallel commission report that allegedly concealed fraudulent transactions resulting in loss of over UGX 1.2 billion. The Labour Officer found the dismissal procedurally unfair: the Claimant had not been properly served with the disciplinary hearing invitation, was not aware of the full charges, was not given sufficient time to prepare his defence, and was not advised of his rights. The Industrial Court upheld the Labour Officer's award on appeal in February 2023. The Respondent subsequently paid the Claimant UGX 223,679,286 in terminal benefits, severance, notice pay, and statutory compensation. The Claimant then filed this reference seeking UGX 3,000,000,000 in general and aggravated damages for reputational harm, emotional distress, financial hardship, and alleged public association with fraud. Evidence showed the Claimant secured re-employment as a Data Warehousing Specialist at PostBank Uganda Limited.
Issues
- Whether the Claimant is entitled to general damages?
- Whether the Claimant is entitled to aggravated damages?
- Whether the Claimant is entitled to costs?
Orders
- The Claimant is awarded UGX 31,030,000 (shillings thirty-one million thirty thousand only) in general damages.
- The claim for aggravated damages is denied.
- The claim for costs is denied.
- Each party shall bear their own costs.
Rules and key headnotes
Legislation cited (8)
Cases cited (18)
- Uganda Post Ltd v Consolate Mukadisi (Supreme Court Civil Appeal No. 13 of 2022)
- Uganda Development Bank v Florence Mufumba (Court of Appeal Civil Appeal No. 241 of 2015)
- Frederick J.K. Zaabwe v Orient Bank (Supreme Court Civil Appeal No. 4 of 2006)
- Obongo v Municipal Council Kisumu [1971] EA 91
- Dr. Wenceslaus Rama Makuza v CAA (Labour Dispute Reference No. 041 of 2019)
- Sserunjogi v Guinness Transporters Ltd t/a Safe Boda
- Stanbic Bank (U) Limited v Okou [2023] UGCA 100
- Attorney General of Uganda v Kwesiga Precious [2025] UGCA 321
- Mutwazagye Nicholas v Electoral Commission [2025] UGCA 290
- Standard Chartered Bank v Makoko [2025] UGCA 115
- Airtel Uganda Limited v Katongole
- Aporo v Mercy Corps Uganda
- Donoghue v Stevenson (1932) A.C 562
- Bank of Uganda v Betty Tinkamanyire [2008] UGSC 21
- Ababiku v Ariyo [2017] UGHCEP 2
- Kalule v Deustche Gesellschaft Fuer Internationale Zuzammenarbeit (GIZ) GMBH
- Nganda Joweria v Allen VR Stanley
- Kansiime Nicholas v Kyenjojo
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.