Wakilii

Uganda National Roads Authority v Multiline Construction Company Limited (Miscellaneous Cause 103 of 2023)

High Court · [2024] UGCOMMC 266 · 2024 Application Granted — Award Set Aside AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application arising from arbitration proceedings seeking declarations concerning the arbitrator's jurisdiction and composition of arbitral panel
Decision
Award set aside; matter remitted to arbitration by a panel of three arbitrators as originally ordered by the court

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The High Court held that the arbitrator acted in contempt of court by proceeding as a sole arbitrator when the court had expressly ordered that the matter be handled by a panel of three arbitrators. The court declared that the arbitrator had no jurisdiction to hear the matter as a sole arbitrator and set aside the award. The court applied the principle that a party who knows of a court order cannot disobey it on the grounds that they regard it as irregular, and that a court cannot sanction what is illegal once it has been brought to its attention.

Outcome

Award set aside; matter remitted to arbitration by a panel of three arbitrators as originally ordered by the court

Facts

The parties entered into a construction contract which gave rise to a dispute. The dispute was referred to adjudication and subsequently to arbitration. The Respondent applied to court to appoint an arbitrator after CADER failed to do so. On 15 May 2023, the court ordered that the Respondent appoint an arbitrator within 2 weeks, who would together with Mr. Derrick Lufunya appoint a third arbitrator, and that the panel of three arbitrators should make their decision within 60 days. The Applicant was not served with the ruling. Mr. Lufunya proceeded as a sole arbitrator on the basis that the Applicant had not nominated an arbitrator within the 2 weeks. The Applicant objected to his jurisdiction but Mr. Lufunya dismissed the objection and proceeded to issue an award on 23 November 2023. The Applicant then brought this application challenging the arbitrator's jurisdiction.

Issues

  1. Whether the Learned Arbitrator had jurisdiction to hear the application as a sole arbitrator where the court had ordered arbitration by a panel of three arbitrators.
  2. Whether the affidavit sworn by Mr. Henry Muhangi should be struck off the record for lack of authority.
  3. Whether the court has jurisdiction to entertain the application where an arbitral award has already been issued.
  4. Whether the arbitrator acted in contempt of court by proceeding as a sole arbitrator contrary to the court's order.

Orders

  • The award by Eng. Derrick Lufunya dated 17 November 2023 is hereby set aside.
  • The Respondent to appoint an arbitrator within 2 weeks.
  • The arbitrator appointed by the Respondent should together with Eng. Henry Alinaitwe appoint a third arbitrator within two weeks from the date of appointment.
  • The arbitrators should make their decision within 90 days from the date of constitution of the panel.
  • The Respondent shall pay the costs of the Applicant.

Rules and key headnotes

Arbitration & ADR — Jurisdiction of Arbitrator — Compliance with Court Orders — Contempt of Court
An arbitrator who is aware of a court order directing that a matter be handled by a panel of three arbitrators acts in contempt of court by proceeding as a sole arbitrator, and consequently has no jurisdiction to issue an award.
Civil Procedure — Contempt of Court — Duty to Comply with Court Orders
A party who knows of a court order, regardless of whether in that party's view the order is null or valid, regular or irregular, cannot be permitted to disobey it by reason of what that party regards the order to be. The order must be complied with in totality, and any party finding compliance not possible for genuine reason must move the court issuing the order and bring to the court's attention the reasons for non-compliance.
Arbitration & ADR — Setting Aside Awards — Lack of Jurisdiction
Where an arbitrator acts without jurisdiction by disobeying a court order, the resulting award is illegal and must be set aside once the illegality is brought to the court's attention.
Civil Procedure — Affidavits — Authority to Swear Affidavit on Behalf of Corporate Body
Where an affidavit is sworn by a legal officer of a corporate entity in their capacity as such, the fact that the deponent is an employee of the entity is evidence enough that they are authorised to swear the affidavit on behalf of the entity unless evidence is adduced to the contrary.

Legislation cited (5)

Cases cited (3)

  • Housing Finance Bank Ltd v Edward Musisi (Miscellaneous Application No. 158 of 2020)
  • Makula International Ltd v His Eminence Cardinal Nsubuga & Anor [1982] HCB 11
  • CHUK CREMET (1 Corp Jemp 342)

Full judgment

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The original judgment as reported. Read the original PDF before relying on any passage.

Uganda National Roads Authority v Multiline Construction Company Limited (Miscellaneous Cause 103 of 2023) [2024] UGCommC 266 (3 September 2024)
Source: this page presents Wakilii’s issue analysis and metadata for a publicly reported Ugandan judgment. Any AI-generated summary is marked as such. Judgment text is sourced from the Uganda Legal Information Institute (ulii.org). Wakilii is not affiliated with ULII.