Rio Insurance v Uganda Revenue Authority - (High Court Civil Appeal No. 12 of 2000)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
An appeal cannot be lodged and prosecuted exparte. Both the Tax Appeals Tribunal Act section 28(1) and the Civil Procedure Rules Order 39(2) require notice of appeal to be served on the party to the proceedings in the court below. Even where the opposite party was excluded from trial proceedings by default, notice of appeal must be served on that party. The Tribunal acted properly in requiring the appellant to prove its claim exparte rather than entering default judgment, as the question before the Tribunal was whether the appellant was liable to pay the sum, not a liquidated claim for refund.
Outcome
Appeal dismissed and matter remitted to the Tax Appeals Tribunal to hear the appellant's case exparte
Facts
Rio Insurance stood as surety for a third party who declared a consignment of 40,000 litres of petroleum product in transit to Rwanda. The appellant executed a bond for UGX 24,546,000 being customs dues payable if the fuel did not transit to Rwanda. The fuel never exited Uganda and the appellant was forced to pay on the bond. The appellant appealed to the Tax Appeals Tribunal contesting its liability to pay. The Uganda Revenue Authority did not file its defence in time and was excluded from the proceedings. The appellant argued it was entitled to default judgment without further proof. The Tribunal ruled that the matter would proceed exparte but required the appellant to prove its claim. The appellant applied for review seeking an order of default judgment, which the Tribunal dismissed. The appellant then filed notice of appeal to the High Court styled as an exparte appeal.
Issues
- Whether an appeal from the Tax Appeals Tribunal can be lodged and prosecuted exparte without serving notice of appeal on the opposite party.
- Whether the Tax Appeals Tribunal was correct to require the appellant to prove its claim exparte rather than entering default judgment where the Uganda Revenue Authority failed to file a defence in time.
Orders
- Appeal dismissed.
- Case remitted to the Tax Appeals Tribunal to proceed to hear the appellant's case exparte.
- Appellant to pay the costs of the failed appeal.
Rules and key headnotes
Legislation cited (7)
- Tax Appeals Tribunal Act s.28(1)
- Civil Procedure Act s.83
- Civil Procedure Rules Order 9(4)
- Civil Procedure Rules Order 6
- Civil Procedure Rules Order 39(2)
- Civil Procedure Rules Order 42 rule 3(2)
- Tax Appeal Tribunal Rules 1999 Rule 30
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.