Testmony Motors Ltd v Commissioner Customs Uganda Revenue Authority (Civil Suit No. 4 of 2011)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that an originating summons is not the proper procedure for challenging the lawfulness of an administrative act as ultra vires an Act of Parliament. Order 37 rule 6 of the Civil Procedure Rules permits originating summons only for determination of questions of construction arising under a deed, will, or other written instrument. A question of construction requires a genuine controversy as to the meaning, scope, or intention of the instrument. The plaintiff's case did not raise a question of construction of the East African Community Customs Management Act 2004, but rather challenged the Commissioner's directive as unlawful. The court held that the words 'other written instrument' in Order 37 rule 6 must be interpreted ejusdem generis as referring to private documents of the nature of deeds and wills, and do not include an Act of Parliament. Originating summons struck out with no order as to costs. Plaintiff at liberty to file a suit in the ordinary manner.
Outcome
Originating summons struck out. Plaintiff at liberty to file a suit by plaint in the ordinary manner.
Facts
Testimony Motors Ltd, on behalf of itself and numerous importers of used motor vehicles in Uganda, sought to challenge a directive by the Commissioner of Customs suspending the transaction value method for valuation of used motor vehicles under section 122 of the East African Community Customs Management Act 2004. On 8 April 2011, the plaintiff obtained leave to sue by representative action. On 15 April 2011, the plaintiff filed an originating summons under Order 37 rules 6 and 8 of the Civil Procedure Rules. On 24 June 2011, the court refused leave to issue the originating summons on the ground that the High Court should not interpret East African Community law, a matter for the East African Court of Justice. Following a review application (Miscellaneous Application No. 397 of 2011), the court allowed the review on 14 October 2011, holding that section 220(1) of the Act conferred jurisdiction on the High Court. The originating summons was signed on 14 October 2011 and served on the defendant. The plaintiff sought declarations that the Commissioner's directive was unlawful and claimed refund of monies allegedly illegally collected. The defendant filed a preliminary objection on grounds that the dispute was improperly brought by originating summons and that the representative order was not properly obtained.
Issues
- Whether the dispute before court is properly brought by way of originating summons.
- Whether the court is functus officio in respect of the procedure adopted after granting leave to issue the originating summons.
- Whether Order 37 rule 6 of the Civil Procedure Rules permits proceedings by originating summons for interpretation of an Act of Parliament.
- Whether the words 'other written instrument' in Order 37 rule 6 include an Act of Parliament.
- Whether the questions framed by the plaintiff constitute questions of construction arising under a written instrument.
Orders
- The originating summons is struck out.
- No order as to costs.
- The plaintiff is at liberty to file a suit for declarations of the legality or illegality of any act of the Commissioner of Customs and for consequential relief.
Rules and key headnotes
Legislation cited (14)
- Civil Procedure Rules Order 37 rule 6
- Civil Procedure Rules Order 37 rule 8
- Civil Procedure Rules Order 37 rule 11
- Civil Procedure Rules Order 6 rule 28
- Civil Procedure Rules Order 6 rule 29
- East African Community Customs Management Act 2004 s.122
- East African Community Customs Management Act 2004 s.220
- East African Community Customs Management Act 2004 s.253
- Judicature (Judicial Review) Rules 2009 rule 5
- Constitution of the Republic of Uganda article 28
- Constitution of the Republic of Uganda article 50
- Constitution of the Republic of Uganda article 137
- Interpretation Act Cap 3 s.2
- Interpretation Act Cap 3 s.14
Cases cited (14)
- Bhari v Khan [1965] EA 95
- Steven Mabosi v Uganda Revenue Authority (Supreme Court Civil Appeal No. 26 of 1995)
- Utex vs. Attorney General
- Environmental Action Network Action Ltd v Attorney General and NEMA (Miscellaneous Application No. 39 of 2001)
- Goodman Agencies v Attorney General (Constitutional Petition No. 3 of 2008)
- Nakabugo v Francis Drake Serungjogi [1981] HCB 58
- Talyaba Nyakana v Beatrice Kobusingye (Civil Suit No. 6 of 1992)
- Pearl Impex v Kampala Capital City Authority (Originating Summons No. 3 of 2011)
- Rock Petroleum v Uganda Revenue Authority (Originating Summons No. 9 of 2009)
- Ismail Serugo v Kampala City Council and Attorney General (Supreme Court Constitutional Appeal No. 2 of 1998)
- Emmanuel Nagoli v Attorney General and Manafwa Dealers Ltd (Constitutional Reference No. 7 of 2006)
- Attorney-General v HRH Prince Ernest Augustus of Hanover [1957] 1 All ER 49
- Bourne (Inspector of Taxes) v Norwich Crematorium Ltd [1967] 2 All ER 576
- Pearl Impex Uganda Ltd v Attorney General and Kampala City Council
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.