Secretary General of East African Community v Zziwa (Taxation Reference No.1 of 2019)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The Court held that the Taxing Officer failed to adequately consider the principle of consistency in awarding instruction fees and placed undue weight on the novelty of the proceedings rather than their complexity. The Court reduced the instruction fees from USD 251,312.58 to USD 140,000 plus getting up fees of USD 35,000. The Court declined to interfere with the award of VAT and disbursements. Each party was ordered to bear its own costs.
Outcome
Instruction fees reduced from USD 251,312.58 to USD 140,000; getting up fees set at USD 35,000
Facts
The Secretary General of the East African Community challenged a taxation ruling awarding instruction fees of USD 251,312.58 (which with VAT and getting up fees totaled USD 359,376.99) to Margaret Zziwa. The taxation arose from Reference No. 17 of 2014, which involved the removal of the sitting Speaker of the East African Legislative Assembly. The Applicant argued that the Taxing Officer failed to apply proper principles, took irrelevant matters into account, and made mathematical errors. The Respondent defended the award as fair and reasonable given the complexity and novelty of the underlying reference, which involved groundbreaking precedents including the first award of monetary damages by the EACJ.
Issues
- Whether the instruction fees awarded by the Taxing Officer were excessive and arrived at by applying erroneous principles.
- Whether the Taxing Officer made a mathematical error in totaling the sums awarded.
- Whether the application was procedurally competent despite reference to inapplicable rules.
- Whether the failure to attach the Bill of Costs, Order, and Proceedings was fatal to the application.
Orders
- Taxation Reference allowed.
- Instruction fees awarded by the Taxing Officer on 4 June 2019 set aside.
- Instruction fees of USD 140,000 awarded.
- Getting up fees of USD 35,000 (one quarter of instruction fees) awarded.
- No interference with other aspects of the Taxing Officer's ruling, including VAT and disbursements.
- Each party to bear its own costs.
Rules and key headnotes
Legislation cited (11)
- East African Court of Justice Rules of Procedure, 2013 r.114
- East African Court of Justice Rules of Procedure, 2013 r.84(1)
- East African Court of Justice Rules of Procedure, 2013 r.84(2)
- East African Court of Justice Rules of Procedure, 2013 r.85(1)
- East African Court of Justice Rules of Procedure, 2019 r.136
- East African Court of Justice Rules of Procedure, 2019 r.130(1)
- East African Court of Justice Rules of Procedure, 2019 r.130(2)
- East African Court of Justice Rules of Procedure, 2019 r.4
- East African Court of Justice Rules of Procedure, 2019 r.129
- East African Court of Justice Rules of Procedure, 2019 Third Schedule r.9
- East African Court of Justice Rules of Procedure, 2019 r.127
Cases cited (7)
- Kenya Ports Authority v Modern Holdings Limited (Taxation Reference No. 4 of 2010)
- Democratic Party and Another v Attorney General of Uganda (Taxation Reference No. 3 of 2013)
- Njuba v Sebalu (Taxation Cause No. 1 of 2013)
- Twinobusinge Saverino v Attorney General (Constitutional Reference No. 27 of 2013)
- Premchand Raichand Limited and Another v Quarry Services of East Africa Limited and Others (No. 3) (1972) EA 162
- Anyang Nyong'o and Others v Attorney General of Kenya and Others (Taxation Reference No. 5 of 2008)
- Alcon International Limited v Standard Chartered Bank (Uganda) and Others (Taxation Reference No. 1 of 2014)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.