Rukwira v Uganda Revenue Authority (Civil Suit 434 of 2020)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The High Court dismissed the plaintiff's suit for breach of contract arising from termination of his secondment to Uganda Revenue Authority. The court held that a UPDF officer seconded to URA under a tripartite employment arrangement has no cause of action against URA when his employment is terminated by UPDF's de-secondment order. The secondment contract expressly provided for termination at the instance of either URA or UPDF, and UPDF retained authority over the plaintiff's service throughout. The court held that URA was merely complying with UPDF's de-secondment directive and had not breached the contract, as the terms made the secondment subject to UPDF authority.
Outcome
Plaintiff's suit dismissed with costs to the defendant
Facts
The plaintiff, a serving UPDF officer, was seconded to Uganda Revenue Authority in October 2015 under a Memorandum of Understanding between the Ministry of Defence and URA. He was appointed on secondment in the Customs Department, and in August 2018 executed a bonding agreement for four years. In September 2018, he was granted paid study leave for one year to pursue a Master's degree in Japan, and his contract was renewed for two years effective December 2018. On 25 May 2020, the Joint Chief of Staff of UPDF de-seconded the plaintiff and 18 other UPDF personnel back to the Defence Forces for other assignments. On 23 June 2020, URA informed the plaintiff of his de-secondment and paid terminal benefits. The plaintiff's letter of appointment expressly provided that his secondment was subject to termination at the instance of either URA or UPDF. The plaintiff filed suit alleging wrongful termination and breach of contract, claiming he had acquired a bank loan guaranteed by salary payments and that the defendant had requested a report on his newly acquired skills. The defendant contended that UPDF had recalled the plaintiff and that it had no authority to retain him after the de-secondment order.
Issues
- Whether the plaint discloses a cause of action against the defendant?
- Whether the plaintiff was lawfully de-seconded by the defendant to Uganda People's Defence Forces?
- Whether there was breach of contract by the defendant?
- Whether the defendant is liable for loss and damages, if any suffered by the plaintiff?
- What remedies are available to the parties?
Orders
- Suit dismissed.
- Costs awarded to the defendant.
Rules and key headnotes
Legislation cited (6)
- Uganda Peoples's Defence Forces Act s.38(2)
- Employment Act s.25(2)(c)
- Leadership Code Act
- Uganda Peoples's Defence Forces Act s.38
- Uganda Peoples's Defence Forces Act s.87
- Uganda Peoples's Defence Forces Act s.88
Cases cited (12)
- Auto Garage v Motokov (1971) EA 514
- Kapeka Coffee Works Ltd v NPART (Court of Appeal Civil Appeal No. 3 of 2000)
- Serugo Ismael v Kampala City Council & Anor (Constitutional Appeal No. 2 of 1998)
- Kampala Rugby Union Football Club v Capital Ventures International Ltd (Miscellaneous Application No. 523 of 2011)
- Maximov Oleg Petrovich vs Premchandra Shenoi & Anor[1998]I KALR 52
- Major General David Tinyefunza v Attorney General (Constitutional Appeal No. 1 of 1997)
- Drummond Jackson vs British Medical Association [1970] 1 All E R 1094
- Tororo Cement Co Ltd v Frokina International Ltd (Civil Appeal No. 2 of 2001)
- Stanbic Bank Ltd v Kiyimba Mutale (Supreme Court Civil Appeal No. 2 of 2010)
- Makubuya Enock v Songdoh Films (U) Ltd & Another (High Court Civil Suit No. 349 of 2017)
- Golden Const. Co Ltd v Stateco (Nig) Ltd (2014) 8 NWLR (pt 1408) p. 171
- National Bank of Kenya v Pipe Plastic Sankolit (K) Ltd & Anor [2001] EA
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.