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Uganda Judgment

Commercial Court of Uganda

Kibibu Engineering Co. Ltd v Kolin Insaat Turizim Sanayi Ticaret (Miscellaneous Application No. 330 of 2016) [2016] UGCommC 80 (20 May 2016)

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01

Holding and result

The court found that the respondent, despite being a foreign company, demonstrated sufficient assets within Uganda, including vehicles and construction equipment registered in its name. The court was persuaded that the respondent had no intention of leaving the jurisdiction and possessed the capacity to meet any obligations arising from the arbitral award. Therefore, it was not proper to order the respondent to provide security for payment, and the application was dismissed.

Court disposition

application dismissed

Orders

  • The application for security for payment is dismissed.
  • No order as to costs.

02

Material facts

Parties

Kibibu Engineering Co. Ltd

Applicant

Kolin Insaat Turizim Sanayi Ticaret

Respondent

03

Procedural history

  1. Posture

    Miscellaneous Application / Ruling on Application for Security for Payment Pending Arbitration Award Enforcement

04

Questions and positions

Legal issues

Party arguments

Applicant
The applicant argued that the respondent is a foreign company with no known assets in Uganda, making it difficult to recover the arbitral award and costs if the respondent fails to pay. The applicant sought an order for the respondent to provide security for the payment of the decree and likely costs.
Respondent
The respondent contended that it has the capacity to satisfy the decree as it owns sufficient assets in Uganda, including debts, vehicles, and construction equipment. Certified copies of vehicle and plant registrations in the respondent's name were provided to the court.

05

Court’s reasoning

  1. 01

    Section 34(5) of the Arbitration and Conciliation Act

    The court may require a party to provide appropriate security if it considers it proper.

  2. 02

    Judicial practice under Ugandan law

    Courts exercise discretion to order security where the party resides outside the jurisdiction and has no substantial property within the jurisdiction.

06

Ratio, limits and disposition

Ratio decidendi

The court found that the respondent, despite being a foreign company, demonstrated sufficient assets within Uganda, including vehicles and construction equipment registered in its name. The court was persuaded that the respondent had no intention of leaving the jurisdiction and possessed the capacity to meet any obligations arising from the arbitral award. Therefore, it was not proper to order the respondent to provide security for payment, and the application was dismissed.

Court disposition

application dismissed

  • The application for security for payment is dismissed.
  • No order as to costs.

Source and reliance status

Commercial Court of Uganda

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Source document

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Judgment text

The complete available source text.

Source document

Commercial Court of Uganda

Judgment

[2016] UGCommC 80

THE REPUBLIC OF UGANDA

IN THE HIGH COURT OF UGANDA AT KAMPALA

MISCELLANEOUS APPLICATION No. 330 OF 2016

*[Arising out of Misc. cause No. 4 of 2016]*

*[ARISING OUT OF CADER/ARBITRATION No. 16 OF 2016]*

*[ARISING OUT OF H. C. C. C No. 172 OF 2013]*

KIBIBU ENGINEERING CO. LTD ::::::::::::::::::::::::::::::::::::::::::::::::: APPLICANT

VERSUS

KOLIN INSAAT TURIZIM SANAYI TICARET ::::::::::::::::::::::::::::::: RESPONDENT

BEFORE: HON. MR. JUSTICE B. KAINAMURA

RULING

This is an application by Ms. Kabibu Engineering Co. Ltd under S. 34 (5) of the Arbitration and Conciliation Act for the applicant. In Misc Cause No. 4 of 2016 M/s Kolen Insaat Turizm Sanayi ve Ticaret to provide security for the payment of the decree in CADER/Arbitration No. 16 of 2016 and costs likely in opposing Misc Cause No. 4 of 2016.

It is contended by the applicant in this application that the respondent is a foreign company with no known assets is Uganda to which the applicant can have resort to, to recover the decretal award and costs.

In reply the respondent maintains it has capacity to satisfy the decree that has been issued against it as it owns sufficient assets in Uganda in form of debt, movable assets like vehicles and construction equipment.

S. 34(5) of the Arbitration and Conciliation Act provides that if the court considers it proper then it can require a party to provide appropriate security.

In practice courts have exercised the above discretion where the party against whom the application is made ordinary resides outside the jurisdiction and has no substantial property within the jurisdiction. In the instant case Counsel for the respondent supplied to court certified copies of a sizeable number of vehicles and plant registered in the names of the respondent.

In the premis I am persuaded that the respondent has no intention of leaving jurisdiction and has sufficient capacity to meet the obligations that may arise if the application to set aside the award was to fail.

Accordingly this application does not succeed and is dismissed with no order as to costs.

B. Kainamura

Judge

20.05.2016

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Authorities

Authorities used by the court

Cases, legislation, regulations, and constitutional provisions identified in the available record.

Arbitration and Conciliation Act, Section 34(5)

Legislation

Legislation referenced in the available case record.

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