KAMPALA, Uganda — The Industrial Court has ruled that unsigned employment contracts do not necessarily mean there is no employer employee relationship, ordering a Kampala based international school to pay more than US$5,000 in unpaid wages to two former British teachers after a dispute that has stretched for nearly nine years.
In a judgment delivered on June 18, 2026, Justice Anthony Wabwire Musana held that Kings International School Limited employed Jane Dicker and James Connolly despite the absence of signed contracts, finding that the parties’ conduct clearly established a valid employment relationship.
The case arose from a labor dispute dating back to 2017 when the two educators were recruited from the United Kingdom to serve as Academic Manager and Mentor, and Head Teacher, respectively. Their appointment letters provided for a monthly salary of US$1,500, accommodation, medical benefits and work permits.
The teachers later accused the school of changing employment terms without consultation and failing to pay agreed salaries. Dicker claimed she was instructed through a text message and email not to return to work, while Connolly argued that persistent salary arrears made it impossible for him to continue working and eventually forced him to return to the United Kingdom.
The school rejected the allegations, maintaining that the pair had served as volunteers who received allowances whenever finances permitted. It further sought US$60,000 in damages, alleging that the teachers damaged its reputation and contributed to a decline in student enrollment after leaving.
However, the court found that the evidence painted a different picture.
In a ruling that could have implications for employment disputes beyond the education sector, Justice Musana emphasized that employment relationships are not determined solely by signed paperwork. Instead, courts may examine the overall conduct of the parties, including the work performed and remuneration paid.
“The Respondent’s defence that the Claimants were mere volunteers is not tenable in law,” the court held.
The judge noted that both teachers carried out senior academic responsibilities and received payments matching the US$1,500 monthly remuneration stipulated in the school’s employment offer letters. Those facts, the court found, were sufficient to establish an employer employee relationship.
Labor experts say the ruling reflects a growing trend in employment law, where courts increasingly focus on the substance of a working relationship rather than its label. According to the International Labour Organization, disputes involving unpaid wages remain among the most common labor complaints worldwide, with informal or poorly documented employment arrangements often becoming a source of litigation.
The judgment also comes at a time when many private schools across Africa continue to rely on a mix of formal staff, volunteers and short term workers, creating legal questions when employment terms are unclear or inadequately documented.
Although the court agreed that the school had failed to meet its salary obligations, it stopped short of finding that the teachers had been unlawfully terminated.
Justice Musana noted that both Dicker and Connolly admitted during testimony that they decided not to return to work because they had lost confidence in the school’s management and were frustrated by unpaid wages. As a result, the court concluded that they voluntarily withdrew their services rather than being formally dismissed.
Nonetheless, the court held that wages earned during their period of service remained legally payable.
Dicker was awarded US$2,662 in unpaid wages, while Connolly was awarded US$2,447. Both awards will attract interest at six percent per annum from November 26, 2017, until full payment is made.
The court also dismissed the school’s counterclaim in its entirety. Claims that the former teachers had spread damaging information through WhatsApp messages were rejected after the court found that the electronic evidence had not been properly authenticated and did not directly identify either teacher as the source.
An attempt to recover alleged outstanding school fees was similarly dismissed after the court ruled that the claims had not been properly pleaded during the proceedings.
According to one of the lawyers, “The decision reinforces a key principle in Uganda’s employment law: employers cannot avoid statutory obligations simply because employment documents remain unsigned if workers have already been recruited, assigned duties and compensated for their services.”
For employees, the ruling serves as a reminder that courts may recognize and enforce employment rights even where formal contracts are incomplete. For employers, it underscores the importance of maintaining clear documentation, timely salary payments and transparent employment practices.
The Industrial Court ultimately ordered Kings International School to pay the outstanding wages, accrued interest and legal costs, bringing to an end a case that has tested the boundaries between volunteer service and formal employment under Ugandan law.
