High Court Labour Division

High Court Labour Division is responsible for hearing and determining employment disputes. It was first inaugurated and launched in June 2007 under the Employment and Labour Relations Act.

65 judgments
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65 judgments
Citation
Judgment date
October 2022
31 October 2022
Whether the arbitrator correctly evaluated evidence and the employer discharged its burden to justify fair termination.
* Labour law – unfair termination – substantive and procedural fairness under section 37(2) Cap 366. * Evidence – evaluation of oral and documentary evidence; admission in CMA Form No.1 and need for corroboration on denial. * Burden of proof – employer’s duty to prove valid and fair reasons for termination; no impermissible shifting found. * Proof issues – relevance of phone records and proof of service of internal memoranda when facts are undisputed. * Judicial review – scope of High Court revision of CMA awards on questions of evidence and fairness.
31 October 2022
31 October 2022
Appeal dismissed: assessors' opinions were read, Tribunal properly preferred eyewitness evidence; no locus in quo visit required.
Land dispute — boundary identification by boundary tree — assessment of credibility: eyewitness evidence v. hearsay; assessors' opinions read and recorded — locus in quo visit discretionary, exceptional circumstances required; appellate re-evaluation of evidence.
31 October 2022
Prosecution proved unlawful possession of elephant tusks; cautioned statement and seizure lawful, appeal dismissed.
Wildlife law – unlawful possession of government trophy; admissibility of cautioned statements – timing and repudiation inquiry; arrest, search and seizure; chain of custody; credibility of independent witnesses; valuation and forensic identification of elephant tusks.
31 October 2022
Applicant failed to account for delay; court dismissed application for extension of time to file revision.
Extension of time — discretion — applicant must show sufficient reasons and account for each day of delay; alleged illegality must be apparent on the record to justify enlargement; lack of funds or union support not ordinarily sufficient without particularised evidence; prior unsuccessful proceedings and failure to pursue proper appeal relevant.
31 October 2022
A CMA award based on unpleaded constructive termination and unsworn testimony was nullified and the award quashed.
Employment law – Pleadings and scope of dispute at CMA; constructive termination vs breach of contract – Part B of CMA F1 mandatory for termination claims; parties bound by their pleadings; mandatory oath/affirmation for witnesses – failure vitiates proceedings; irregular record‑keeping and unsworn testimony as grounds for nullification.
31 October 2022
Technical delay from a struck-out timely revision was excused; the applicant granted extension to file revision.
* Civil procedure – extension of time – technical delay where an original revision was timely filed but struck out for procedural defects – striking out as sufficient penalty. * Labour law – revision of CMA award – notice of intention to seek revision – consequences of non-compliance. * Requirement of diligence and prompt action after procedural setback. * Illegality as separate ground not necessary where extension is justified by technical delay.
28 October 2022
Revision dismissed: extension denied due to unexplained delay, dishonest affidavit, and abuse of process.
Labour law — extension of time — requirement to account for each day of delay; affidavits tainted with falsehoods cannot be acted upon; illegality must be pleaded not merely argued orally; abuse of process and omnibus applications in enforcement disputes.
28 October 2022
28 October 2022
Representative suit complied with rule 5; no proof of settlement, revision dismissed.
Labour law — representative suit: CMA proceedings informal; representative suits governed by Labour Institutions (Mediation and Arbitration) Rules 2007 r.5(1)–(3) — list and signatures required; Evidence — party alleging prior settlement must tender proof; failure to produce settlement agreement entitles CMA award to stand; Costs — each party to bear own costs in labour matters.
28 October 2022
Technical delay from withdrawal of a defective CMA form justified extension of time and the CMA's refusal was quashed.
Labour law – condonation for late filing – Rule 10(1),(2) GN No.64/2007 – technical delay due to withdrawal of defective CMA Form No.1 – Lyamuya principles on extension of time – discretion to grant condonation – remittal for mediation.
28 October 2022
Assault at work justified dismissal and procedural fairness met despite differing show‑cause wording.
Employment law – termination for gross misconduct (assault); procedural fairness under Employment and Labour Relations Act and G.N. No. 42/2007; show‑cause letter versus charge sheet; employer’s burden of proof under section 39.
28 October 2022
Criminal trespass conviction quashed where accused raised genuine belief in land ownership; ownership must be resolved civilly first.
Criminal law – criminal trespass and theft – where question of land ownership arises court must not decide ownership in criminal proceedings; defendant's genuine belief in ownership requires civil determination first; onus remains on prosecution to prove offences beyond reasonable doubt.
28 October 2022
Termination was substantively justified but procedurally unfair; claimant awarded six months' salary and a certificate of service.
Employment law – unfair termination – substantive fairness v procedural fairness; typographical error in charge sheet not fatal where identity is clear; obligation to supply investigation report; right to mitigation before sanction; remedy by compensation where termination substantively fair but procedurally irregular.
28 October 2022
Termination allegedly for CPA lack was substantively and procedurally unfair; CMA award upheld.
Employment law — unfair dismissal; retrenchment/operational requirements — compliance with section 38 (notice, disclosure, consultation, selection); evidentiary burden for employer; waiver under duress; reasonableness of qualification requirements.
27 October 2022
Applicant failed to show good cause or account for delay; extension of time to set aside ex parte judgment refused.
Labour law — Extension of time under Rule 56(1) — Requirement to show good cause and account for each day of delay — Non-service of originating process is a substantive ground for setting aside ex parte judgment, not a substitute for good cause in extension application.
27 October 2022
Termination was substantively unfair where employer failed to prove negligence or consistent disciplinary treatment; CMA award upheld.
* Employment law — unfair dismissal — substantive fairness of termination for alleged gross negligence — employer must prove misconduct and that employee was properly trained/aware of duties. * Employment law — disciplinary consistency — employer's inconsistent treatment of similarly situated employees relevant under Rule 12(1)(b)(iv) of the Code. * Remedies — fixed-term contract terminated unfairly — award of salaries for remaining contract period is lawful.
27 October 2022
Revision dismissed: condonation valid, refiling permitted where wrong party was sued, and 15‑month compensation award upheld.
Labour law – condonation for late filing; interlocutory orders – revisability; withdrawal of execution and refiling; mis‑naming a party versus clerical error; jurisdiction and res judicata; evidential burden on employer to produce written contract (s.15(6) ELRA); compensation for unexpired fixed‑term contract.
27 October 2022
A party’s failure to follow up representation and not raising objections at the CMA dooms an application to set aside an ex parte award.
Labour law – revision of CMA decisions – setting aside ex parte award – sufficient cause for non-appearance – duty of parties to follow up representation; procedural complaint not raised at CMA cannot be entertained on revision.
27 October 2022
Applicant failed to prove illness as good cause to restore a struck‑out labour application; restoration dismissed and each party bears own costs.
Labour procedure — restoration of struck‑out file — requirement to show good cause under Rules 36(1) and 38 — evidentiary value of medical/clinic certificate — need for corroboration/timestamp; allegation of forged medical document and absence of police investigation report.
26 October 2022
Employer lawfully dismissed employee for unpaid external loan and reputational risk; procedure and policy incorporation were upheld.
Labour law – termination for misconduct; substantive fairness – employer's onus under s.39; incorporation of employer policies via offer of employment; procedural fairness – Code of Good Practice (G.N. No.42 of 2007, rule 13); evidence of unpaid external loan and reputational risk as grounds for dismissal.
26 October 2022
Probation extension lawful under labour rules; documented poor performance justified termination and CMA award was upheld.
Labour law – probationary period – extension of probation under Rule 10(5) GN.42/2007 – notice of termination – fixed‑term contract – poor performance as justification for termination – review of CMA award.
25 October 2022
Executing officer properly computed and enforced CMA award; respondent’s late reluctance to be reinstated did not defeat award enforcement.
Labour law – Execution of CMA awards – Jurisdiction of executing officer to compute quantum and enforce CMA awards as Labour Court decrees; Effect of employee’s stated unwillingness to be reinstated on entitlement to arrears; Attachment and sale of property to satisfy labour award.
25 October 2022
Employer had valid substantive reason for dismissal but disciplinary procedure was flawed; CMA award reduced to four months' pay.
Labour law – dismissal – substantive fairness established by forensic evidence and recorded communications; procedural fairness breached where investigation report absent and employee not ready for disciplinary hearing – compensation for procedural unfairness; limits on arbitrator’s jurisdiction to grant unpleaded relief (blacklist removal).
25 October 2022
Ex parte award set aside for lack of proof of service; matter remitted to CMA for inter partes rehearing.
Labour law – ex parte awards – requirement of proof of service/notification of hearing and award – revision of CMA ruling – quashing and setting aside ex parte award – remittal for inter partes hearing before another arbitrator.
25 October 2022
Failure to comply with a court-ordered filing deadline rendered the revision application time-barred and dismissible.
* Labour law – revision application – compliance with court order to file within specified time; * Civil procedure – competency of filing – effect of rejected electronic filing; * Time-barred applications – dismissal for non‑compliance with court order; * Respect for court orders – consequences of disobedience.
25 October 2022
CMA award quashed because the respondent was a public servant, failed to exhaust internal remedies, and CMA lacked jurisdiction.
Labour law – jurisdiction of CMA versus Labour Court on collective bargaining agreement interpretation; Public Service Act s32A – exhaustion of internal remedies by public servants before resort to labour laws; condonation – proper assessment of when dispute arose and delay; review – nullification and setting aside of award for lack of jurisdiction.
25 October 2022
Court dismissed applicant’s revision and upheld the respondent’s CMA award for wrongful termination and tort damages.
Labour law — condonation for late filing — sufficient cause where awaiting medical report; Arbitrator’s jurisdiction — framing issues consistent with CMA pleadings and opening statements; Breach of contract — termination without complying with contractual notice; Tortious liability — employer liable for foreseeable stress-related injury; Revision — appellate court will not interfere absent illegality or misdirection.
25 October 2022
Court upheld CMA finding that claimants were casual workers, not employees, and dismissed the revision application.
Labour law — Employment relationship — Section 61 factors for employer–employee presumption; burden of proof where employment is disputed (Evidence Act s110); employer record-keeping duty (ELRA s15) applicable only when employment exists; sufficiency of evidence to prove regular salary versus allowances.
24 October 2022
24 October 2022
Applicant’s 189‑day delay was inordinate and unaccounted for; condonation rightly denied and CMA award upheld.
* Labour law – condonation for late filing – factors under Rule 11(3) – requirement to account for all days of delay. * Civil procedure – extension of time – application of Lyamuya principles: degree of lateness, reasons, diligence and prospects of success. * Judicial review – revision of CMA award – scope limited where mediator properly applied legal tests and recorded evidence.
24 October 2022
Applicant's sickness and remand custody constituted sufficient cause to grant condonation and remit the matter to the CMA on merits.
Labour law – condonation/extension of time – Rule 11 GN No.64/2007; admissibility of evidence at CMA; unchallenged affidavit as proof; sickness, remand custody and community service as sufficient cause; revisional jurisdiction to correct procedural irregularity.
21 October 2022
A limitation-based preliminary objection fails where the date the applicant received the award is disputed and requires evidence.
* Employment law – Review of CMA award – Time limits under section 91 – calculation from date copy of award was given; * Civil procedure – Preliminary objection – distinction between pure points of law and disputed facts; * Principle in Mukisa Biscuit – factual issues requiring evidence cannot be decided on preliminary objection; * Limitation – when awareness/receipt of decision is contested.
21 October 2022
High Court lacks jurisdiction to revise its Deputy Registrar’s execution ruling; revision lies with the Court of Appeal.
Labour law – Execution – Jurisdiction to revise Deputy Registrar’s execution rulings; Rule 28 Labour Court Rules; Order XLIII CPC; inherent jurisdiction; vertical (Court of Appeal) revisional power.
21 October 2022
Revision allowed: arbitration dismissal for being out of time set aside; matter remitted for proper hearing on constructive dismissal and procedure.
* Labour law – constructive dismissal – time limitation for unfair dismissal complaints (30 days) – whether dispute was filed within statutory period. * Procedural fairness – right to be heard – admissibility of written submissions filed without leave. * Administrative law – reliance on extraneous evidence by arbitral tribunal – error of law and remittal for proper hearing.
21 October 2022
Court quashed eviction execution where original drawn order lacked required description of immovable property under Order XX Rule 9 CPC.
Civil procedure — Execution of decrees — Order XX Rule 9 CPC requires decrees concerning immovable property to contain sufficient description and title number; a court cannot, under guise of interpretation, make or import a new decree — executing court must give effect only to terms of the decree — High Court’s revisionary power to quash proceedings infected by material irregularity.
21 October 2022
Failure to frame the central issue and give reasons rendered the CMA award materially irregular and warranted revision and remittal.
Labour arbitration — requirement to frame and narrow issues (Rule 22(2) GN No.67/2007); awards must summarise evidence, arguments and reasons (Rule 27(3)); parties bound by pleadings; failure to ascertain nature/timing of termination affects timeliness; material procedural irregularities justify revision and remittal to CMA.
21 October 2022
Termination found substantively unfair; statutory 12-month compensation upheld, contractual 24-month award set aside.
Employment law – unfair dismissal – substantive fairness where no time-frame specified for task and pandemic context; contractual post-termination restraint – interpretation and limits of clause permitting restriction but not automatic compensation; compensation – statutory 12 months upheld, extra contractual 24 months set aside.
20 October 2022
An appeal to the High Court is incompetent if the appellant failed to seek re-admission after dismissal for non-appearance.
* Civil procedure – Appeal dismissed for non-appearance (Order XXXIX Rule 17 CPC) – Requirement to apply for re-admission under Order XXXIX Rule 19 – Failure to seek re-admission renders subsequent High Court appeal premature and incompetent – Appeal struck out.
20 October 2022
A conciliator lacked jurisdiction to deny extension or issue a one-sided award; the matter is remitted for proper hearing.
* Labour law – jurisdiction of conciliator vs adjudicator (muamuzi) – conciliator lacks power to decide validity of dismissals or grant determinative orders. * Civil procedure – extension of time – delay can be excused where it concerns alleged invalidity of a prior award. * Evidence – taking testimony without oath may vitiate proceedings and awards. * Remedy – setting aside decisions made by an officer without jurisdiction and remitting matter for proper hearing.
19 October 2022
Leave to appeal granted on arguable issues about locus standi and propriety of the High Court's revisional powers.
Land law – leave to appeal – discretionary test for leave – arguable or novel points of law; Revisional jurisdiction – scope and limits – whether tribunal's error amounts to material illegality; Locus standi – substitution/amendment without proof of death or letters of administration; Pleadings – adequacy of description of suit land and consequences.
19 October 2022
When the respondent refuses re‑engagement, Section 40(3)(c) mandates 12 months' compensation plus wages and benefits until refusal date.
* Employment law – ELRA s.40(3)(c) – alternative remedy where employer refuses re‑engagement – twelve months' compensation in addition to wages and benefits due from date of unfair termination to date of final payment. * Cut‑off date for wages/benefits is date employer manifestly refuses re‑engagement, not date of order. * Re‑engagement creates a new relationship but is irrelevant where employer promptly declines; delays by employees should not extend employer liability.
13 October 2022
Applicants’ fixed‑term contracts expired; termination was lawful, CMA award upheld and applicants’ claims dismissed.
Employment law – contract characterization – fixed-term vs permanent contracts – expiry of fixed-term contracts; procedural fairness – opportunity to challenge documentary evidence; CMA award – evaluation of evidence and lawfulness of termination for expiry of fixed-term contracts.
12 October 2022
A tribunal exceeded its jurisdiction by granting leave to refile without condonation or affording parties the right to be heard, so the award was set aside.
Labour law – jurisdiction and limitation – defective CMA Form 1 struck out – granting leave to refile without condonation or hearing exceeds arbitrator’s jurisdiction; natural justice – audi alteram partem – right to be heard before adverse procedural orders; procedure for retrenchment – consultation and evidence of teleconference; remedies – nullification and setting aside of award where jurisdiction lacking.
11 October 2022
Failure to serve the prescribed Form No.10 notice to the CMA is a fatal procedural defect and warranted striking out the application.
* Labour law — Procedural compliance — Rule 34(1) GN. No.47/2017 — Third Schedule forms (Form No.10) mandatory. * Interpretation of Laws Act s.53(2) — "shall" imposes mandatory duty. * Revision applications — failure to serve prescribed notice is fatal — application struck out.
11 October 2022
CMA lacked jurisdiction over a dispute involving a public servant; claims must follow section 32A Public Service Act procedures.
* Labour law – jurisdiction – whether CMA has jurisdiction over disputes involving public servants governed by the Public Service Act (s.32A). * Administrative law – effect of Court of Appeal precedent on jurisdictional competence of arbitration forums. * Procedure – referral of public servant employment disputes to the Public Service Commission under section 32A.
11 October 2022
Court set aside CMA award, finding termination substantively and procedurally unfair and awarding 24 months' compensation.
* Labour law — Unfair termination — employer's duty to prove valid substantive reason (Section 37). * Insubordination — requirement of wilful, gross refusal to follow lawful reasonable instructions; instructions must be reasonable. * Procedural fairness — mandatory investigation under Rule 13(1) of GN No. 42/2007; failure renders process unfair. * Remedies — reinstatement vs compensation under Section 40(1) and terminal benefits under Section 44.
10 October 2022
An unexplained nine-month gap between electronic and physical filing rendered the revision application time-barred as an abuse of process.
* Labour law – Revision of CMA award – Limitation periods – Electronic filing versus physical filing – Unexplained delay between electronic and physical filing – Abuse of court process; computation of time and service of awards.
10 October 2022
Review dismissed as time‑barred under Rule 28(1); filing amounted to abuse of court process.
Labour procedure – Review time limits under Labour Court Rules (Rule 28(1)) – Notice of review must be filed within fifteen days – Time‑barred applications and abuse of court process – Effect of counsel’s concession on competence of proceedings.
10 October 2022