Tullow Uganda Ltd & Anor v Wabyona & Anor (Miscellaneous Application No. 197 of 2017)
Observed later treatment
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Holding
Held that the preliminary objection to the Respondent's locus standi fails because his application is in substance public interest litigation challenging the authority of Uganda Revenue Authority to waive taxes, rather than a conventional review application. Wrong procedure adopted does not defeat the court's inherent jurisdiction where parties have been heard and no injustice results. Article 17 of the Constitution gives citizens standing to challenge alleged breaches of law by public authorities, and the court must lend its processes to the exercise of this constitutional duty. Preliminary objection dismissed with costs.
Outcome
Preliminary objection dismissed; Respondent's application for review of consent judgment to proceed
Facts
The Applicants Tullow Uganda Ltd and Tullow Uganda Operations Pty Ltd entered into a consent judgment with Uganda Revenue Authority on 19 June 2015 resolving a tax dispute. The Respondent Jackson Wabyona, a citizen who was not a party to the proceedings, subsequently filed an application (HCMA 137 of 2017) seeking to review and set aside the consent judgment. Wabyona alleged that the consent judgment constituted a waiver of taxes amounting to over US$471 million, that Uganda Revenue Authority acted ultra vires and contrary to law, and that as a citizen with a duty under article 17 of the Constitution to combat misuse of public property he was aggrieved by the decree. The Applicants filed the present application under Order 6 rule 30 of the Civil Procedure Rules to strike out Wabyona's application on the ground that he lacks locus standi because he is neither an aggrieved person nor a person against whom the decree was passed within the meaning of Order 46 rule 1 of the Civil Procedure Rules.
Issues
- Whether the Respondent has locus standi to apply for review of a consent judgment entered between the Applicants and Uganda Revenue Authority where he was not a party to the proceedings
- Whether a third party can bring an application for review of a decree under Order 46 rule 1 of the Civil Procedure Rules
- Whether article 17 of the Constitution confers standing on a citizen to challenge acts of a public authority as a waste of public resources
- Whether the application for review is the appropriate procedure for a public interest challenge to the acts of Uganda Revenue Authority
Orders
- The preliminary objection is overruled.
- The application to strike out High Court Miscellaneous Application No. 137 of 2017 is dismissed.
- Costs awarded to the Respondent.
Rules and key headnotes
Legislation cited (10)
- Constitution of the Republic of Uganda 1995 article 8A
- Constitution of the Republic of Uganda 1995 article 17
- Constitution of the Republic of Uganda 1995 article 42
- Constitution of the Republic of Uganda 1995 article 50
- Constitution of the Republic of Uganda 1995 article 126(2)(e)
- Constitution of the Republic of Uganda 1995 article 137
- Civil Procedure Act s.82
- Civil Procedure Rules Order 6 rule 30
- Civil Procedure Rules Order 46 rule 1
- Civil Procedure Rules Order 46 rule 8
Cases cited (28)
- Ladak Abdulla Mohammed Hussein v Griffiths Isingoma Kakiiza & 2 Others (SCCA No. 8 of 1995)
- Yusufu v Nokrach (1971) EA 104
- Re Nakivubo Chemists (U) Ltd (1971) HCB 12
- Jinja Municipal Council & Anor v Registered Trustees of the Indian Recreation Club & 2 Others (HCMA No. 66 of 2004)
- R v London Sessions Appeal Committee Ex Parte Westminster City Council [1951] 1 All ER 1032
- Re: Sidebotham (3)
- Ealing Borough Council v Jones [1959] 1 All ER 286
- Mohammed Allibhai v Bukenya & Anor (SCCA No. 56 of 1996)
- Hassanali v City Motor Accessories Ltd & Ors [1972] EA 423
- Hirani v Kassam (1952) 19 EACA 131
- Brooke Bond Liebig (T) Ltd v Mallya [1975] 1 EA 266
- Inland Revenue Commissioners v National Federation of Self-Employed and Small Businesses Ltd [1982] AC 617
- Kikungwe Issa, Salaamu Musumba & Ors v Standard Bank Investment Corporation & Ors (HCMA No. 394 & 395 of 2004)
- Chandrika Prasad versus the Republic of Fiji and the Attorney General of Fiji HCB 0217 of 00L
- Attorney General of Gambia v N'jie [1961] AC 617
- ex parte. Official Receiver in re Reed, Bowen & Company
- Attorney General v Independent Broadcasting Authority [1973] All ER 689
- R v G.L.C. Ex p Blackburn [1976] 1 WLR 550
- Boyes v Gathure [1969] 1 EA 385
- Saggu v Roadmaster Cycles (U) Ltd [2002] 1 EA 258
- Nanjibhi Prabhudas and Company Limited v Standard Bank Limited [1968] EA
- Re Christine Namatovu Tebajjukira [1992-93] HCB 85
- Juandoo v Attorney General of Guyana (1971) AC 972
- Attorney General v Ali & Ors (1989) LRC 474
- Mawji v Arusha General Store [1970] 1 EA 137
- Purcell v F C Trigell Ltd (trading as Southern Window and General Cleaning Co) & Anor [1970] 3 All ER 671
- Huddersfield Banking Co. Ltd v Henry Lister & Son Ltd (1895) 2 Ch D 273
- Ex Parte Sidebotham (1880) 14 Ch D 458
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.