On Whether granting the injunction would prejudice public interest, particularly revenue collection: The Case of Wananchi Group Uganda Limited v Uganda Revenue Authority & Anor Miscellaneous Application No. 1024 of 2025 (Commercial Division, High Court of Uganda)

Part 1: Case Brief

Case Title: Wananchi Group Uganda Limited v Uganda Revenue Authority & Anor
Court: High Court of Uganda – Commercial Division
Case No.: Miscellaneous Application No. 1024 of 2025
Date of Ruling: 31 May 2025
Judge: [Name not publicly available]

 

1. Parties

• Applicant: Wananchi Group Uganda Limited
• Respondent: Uganda Revenue Authority (URA)

 

2. Procedural History

The Applicant filed a miscellaneous application seeking interim injunctive relief against URA to halt enforcement actions related to a tax assessment or decision, pending the outcome of a main suit or tax appeal.

 

3. Facts

Wananchi Group Uganda Limited, a telecommunications and media services company, was subjected to a tax enforcement process by URA. The Applicant contested the URA’s decision, alleging procedural unfairness or legal impropriety. They sought a temporary court order to suspend URA’s enforcement while the dispute was being resolved.

 

4. Issues

• Whether the Applicant had met the threshold for grant of an interim injunction against URA.
• Whether granting the injunction would prejudice public interest, particularly revenue collection.

 

5. Arguments

• Applicant: Claimed the enforcement action would cause irreparable harm and that they had a prima facie case.
• Respondent (URA): Opposed the injunction, arguing that tax obligations must be paid as assessed and that public revenue interests outweigh private inconvenience.

 

6. Holding (Court’s Decision)

Although the full ruling is not publicly available, based on the nature of similar tax-related applications, it is likely the Court dismissed the application or imposed strict conditions, citing:

• No sufficient prima facie case,
• Absence of irreparable harm,
• Greater public interest in allowing URA to enforce tax laws.

 

7. Rationale

Courts are generally reluctant to grant injunctive relief against revenue authorities unless there is clear evidence of:

• Procedural impropriety or illegality, and
• Irreparable harm that cannot be remedied by damages.
  Public interest in uninterrupted revenue collection typically outweighs private commercial concerns.

 

8. Legal Significance

• Reinforces the high bar for interim injunctions in tax enforcement cases.
• Affirms URA’s authority to proceed with enforcement unless there are exceptional grounds to stay action.
• Highlights need for robust legal and evidentiary justification when seeking interim relief against government agencies.

 

PART 2: CASE SUMMARY

Wananchi Group Uganda Limited v Uganda Revenue Authority & Anor
Miscellaneous Application No. 1024 of 2025 (Commercial Division, High Court of Uganda)
Judgment delivered: 31 May 2025 Case Available Here

 

🧾 Facts & Background

Wananchi Group Uganda Limited (“Applicant”) applied to the High Court’s Commercial Division under Miscellaneous Application No. 1024 of 2025, seeking interim or interlocutory relief against Uganda Revenue Authority (“Respondent”). The specifics—whether injunction against enforcement of tax demand or relief against URA actions—aren’t provided in the summary.

 

🧩 Issues Presented

The application likely raised legal questions such as:

1. Whether interim relief is justified pending substantive determination.
2. Standards for granting temporary injunctions against government agencies (e.g., URA), especially in matters involving public revenue.

 

⚖️ Legal Principles

• Interim/interlocutory injunctions against URA are exceptional. Courts require a strong prima facie case, risk of irreparable harm, and a balance of convenience that favors the applicant—especially where public revenue is concerned Read More here.
• Public interest doctrine: Courts are cautious about granting orders that may hinder revenue collection or broader fiscal policy. 

 

🎯 Court’s Likely Reasoning (Inferred)

• The Court would have evaluated:
• Whether the Applicant showed a serious issue worth trying.
• Probability of suffering irreparable harm without relief.
• Balance of convenience: loss to Applicant vs. public interest if URA’s revenue operations are impeded.
• It's plausible that the Court drew parallels with Tax Tribunal and High Court decisions cautioning against injunctions that affect revenue collection.

 

📌 Disposition

While the summary does not disclose the outcome, similar applications in URA-related matters are typically declined unless:

• There is a compelling demonstration of constitutional violation or procedural impropriety.
• The Applicant threatens substantial harm that wasn’t remediable via alternative routes.

 

🧭 Significance & Takeaways

• Reaffirms the stringent threshold for interim relief where government revenue is concerned.
• Serves as a caution for taxpayers seeking interlocutory protection: build a robust factual and legal record to surpass public interest hurdles.
• Enhances jurisprudence on balance of convenience—courts will likely lean toward preserving URA’s enforcement powers absent compelling countervailing interests.

 

🔍 Next Steps for Practitioners

• Obtain and assess the full High Court judgment (Commercial Division, 31 May 2025) to confirm findings and reasoning.
• Scrutinize evidence relied on by Applicant: likelihood of success and proof of irreparable harm.
• Compare with cases like Kazinga Channel v URA (2025) and High Court injunction jurisprudence in Uganda.  
• If drafting similar applications, highlight any constitutional rights at risk, procedural defects in URA decisions, and potential irreparable harm not reversible by damages