KAMPALA, Uganda – A senior Uganda Revenue Authority (URA) manager has been ordered to pay Shs100 million in damages to a colleague after the High Court found that defamatory allegations circulated through a WhatsApp group severely damaged the colleague’s reputation.
In a ruling delivered on June 17, 2026, Justice Bonny Isaac Teko held that James Abola, URA’s Assistant Commissioner for Staff Compliance, defamed Nicholas Jjengo, a tax auditor at the authority, by posting unverified allegations about him in the URA Senior Management WhatsApp forum.
The court’s decision sends a strong message that communications shared on private WhatsApp platforms are not beyond the reach of the law, particularly where they harm another person’s reputation.
The dispute stemmed from messages Abola posted on September 18, 2022, in which he identified Jjengo by name and described him as a customs officer being sought by police.
One of the messages stated that “UPF Kasangati is looking for one Jjengo Nicholas a CUSTOMS OFFICER who shot 3 bullets at some victims last night.”
A second message alleged that Jjengo had pursued another man’s vehicle and fired at it near the victim’s home in Magere following a disagreement involving a woman after a social outing. The posts portrayed him as a violent and reckless individual involved in a love triangle and criminal conduct.
According to court records, the messages were circulated shortly after a work-related disagreement between the two officers.
Jjengo sued for defamation, arguing that the allegations falsely painted him as a wanted criminal, a violent aggressor and an immoral person, causing significant reputational harm among URA’s top leadership.
During the trial, Abola defended his actions, saying he had received the information from ASP Patrick Lumumba Okello, a police officer attached to the Staff Compliance Division, and shared it in good faith within a closed management forum. He argued that the communication was protected by qualified privilege because it concerned staff conduct and security matters. He also maintained that phrases such as “it is alleged” and references to ongoing investigations showed he was merely relaying information rather than asserting proven facts.
However, evidence before the court showed that James Malinzi, then Assistant Commissioner for Risk Management and a member of the WhatsApp group, contacted Jjengo after seeing the messages and was informed that the account was inaccurate. Malinzi testified that he even provided Abola with Jjengo’s telephone contact to verify the claims, but Abola did not follow up and continued circulating the allegations.
Lawyers from Astral Advocates, representing Jjengo, argued that the statements were plainly defamatory, particularly because they were shared among some of URA’s most senior officials. They sought Shs360 million in general damages and Shs50 million in exemplary damages.
Abola’s lawyers from Amber Solicitors & Advocates insisted that he was acting within his official responsibilities and that the use of cautionary language shielded him from liability.
Justice Teko rejected that argument.
In his judgment, the judge found that Abola had acted with reckless disregard for the truth by failing to verify serious allegations despite having both the means and opportunity to do so. He described the narrative shared on WhatsApp as “grave, colourful, sensational and personally destructive.”
The judge emphasized that merely stating that allegations are unverified does not absolve a person from responsibility for republishing defamatory content.
“A person who republishes defamatory allegations cannot escape liability merely by saying that the matter is alleged, especially where the allegation is grave, the audience influential, and the publisher has means of verification,” Justice Teko ruled.
He further noted that qualified privilege protects responsible communication made in good faith, not reckless publication carried out with indifference to the truth.
While assessing damages, the court acknowledged that the allegations involved accusations of criminal conduct, violence and moral impropriety. However, it also noted that the statements were circulated within a restricted internal forum rather than through mainstream media platforms.
Justice Teko awarded Jjengo Shs70 million in general damages and Shs30 million in exemplary damages, bringing the total award to Shs100 million. The amount will attract interest at 8 percent per annum from the date of judgment until full payment.
The court also awarded Jjengo the costs of the suit.
In addition, Abola was ordered to issue a written apology within 14 days and publish it in the same URA Senior Management WhatsApp group where the allegations were shared. A permanent injunction was also issued restraining him from publishing similar allegations against Jjengo unless they are lawfully made, verified, in good faith and within the scope of his official duties.
The case is recorded as Nicholas Jjengo v James Abola (Civil Suit No. 30 of 2023) [2026] UGHCCD 203.
