Tullow Uganda Limited & Anor v Wabyona (Miscellaneous Application No. 393 of 2020)
Observed later treatment
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Holding
Held that the plaint in HCCS No. 296 of 2020 was res judicata and barred by lis alibi pendens because the same matters had been decided in HCCA No. 19 of 2014 and were pending in HCMA No. 137 of 2017. The respondent failed to demonstrate locus standi for a public interest suit as he did not exhaust other remedies or particularise allegations of corruption and fraud. Application allowed and plaint struck out.
Outcome
Plaint struck out as against the applicants
Facts
The respondent filed HCCS No. 296 of 2020 as a public interest suit under Article 17 of the Constitution seeking to invalidate a Settlement Deed executed on 18 June 2015 between Tullow Uganda Limited, Tullow Uganda Operations Pty Ltd, Uganda Revenue Authority, and the Government of Uganda. The Settlement Deed resolved a tax dispute arising from Tullow's farm down of interests, reducing tax liability from USD 542,793,821 to USD 250,000,000 pursuant to a consent order in High Court Civil Appeal No. 19 of 2014. The respondent alleged the Settlement Deed was illegal because it waived taxes without parliamentary approval under Article 152(2) of the Constitution and section 35 of the Public Finance Management Act 2015, and involved corruption and fraud. The respondent had previously filed HCMA No. 137 of 2017 seeking to review the consent decree. The applicants moved to strike out the plaint for being res judicata, lis pendens, and failing to disclose a cause of action.
Issues
- Whether the plaint in HCCS No. 296 of 2020 is res judicata in light of the decree in High Court Civil Appeal No. 19 of 2014.
- Whether the plaint in HCCS No. 296 of 2020 is barred by the lis alibi pendens rule given the pending HCMA No. 137 of 2017.
- Whether the plaint discloses a cause of action.
- Whether the respondent has locus standi to bring a public interest suit under Article 17 of the Constitution.
- Whether allegations of corruption and fraud are sufficiently particularised in the plaint.
Orders
- Application allowed.
- The plaint in High Court Civil Suit No. 296 of 2020 struck out for not disclosing a cause of action and being barred by the lis pendens rule.
- Costs of the application awarded to the applicants.
Rules and key headnotes
Legislation cited (13)
- Civil Procedure Act s.6
- Civil Procedure Act s.7
- Civil Procedure Act s.98
- Civil Procedure Rules Order 6 Rule 3
- Civil Procedure Rules Order 6 Rule 30
- Civil Procedure Rules Order 7 Rule 11(a)
- Civil Procedure Rules Order 52 Rules 1 and 3
- Constitution of Uganda Article 8A
- Constitution of Uganda Article 17
- Constitution of Uganda Article 17(i)
- Constitution of Uganda Article 152(2)
- Public Finance Management Act 2015 s.25
- Public Finance Management Act 2015 s.35
Cases cited (5)
- Kikungwe Issa and 4 Others v Standard Bank Investment Corporation and 3 Others (Miscellaneous Application No. 394/395 of 2004)
- Hon. Abdu Katuntu and Another v MTN Uganda Ltd and 6 Others (HCCS No. 248 of 2012)
- Auto Garage vs Motokov
- Mayanja Hussein v Mubiru Christopher (Civil Suit No. 129 of 2010)
- Fredrick JK Zaabwe v Orient Bank and 5 Others (Supreme Court Civil Appeal No. 4 of 2006)
Cases citing this judgment (1)
How later Ugandan judgments in the Wakilii corpus have cited this case. Treatment labels come from Sequitur — Uganda’s citator — each backed by a verbatim span from the citing judgment, and are not an assertion that this case is, or is not, good law.
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.