Jumatatu, 14 Novemba 2022

NATIONAL MUSEUMS OF TANZANIA LOSES LABOUR BATTLE

By FAUSTINE KAPAMA

The Court of Appeal has ordered the National Museums of Tanzania to pay compensation of 18 months and other unpaid benefits to their former Curator History Grade II, Magreth Mapunda, for illegal termination of her employment services.

Justices Stella Mugasha, Ignas Kitusi and Sam Rumanyika ruled in favour of Magreth, the appellant, after allowing her appeal she lodged to oppose the decision of the High Court, which has reversed the findings of the Commission for Mediation and Arbitration (CMA) on the matter.

“We are satisfied that the termination was both substantively and procedurally unfair, which attracts a heavier penalty as opposed to procedural unfairness. On account of procedural and substantive unfairness, it is deserving that the appellant be paid compensation,” they ruled.

Referring to the provisions of section 37 of the Employment and Labour Relations Act, the justices pointed out that the termination of an employee from employment will be rendered invalid if the employer fails to substantiate the same and if the requisite procedures were not followed.

They revisited the letter allegedly contained the charges and noted the appellant was required to avail explanation as why she did not hand over the office keys while being aware that she was proceeding on leave the reason for accessing the office while she was on vacation.

The justices observed that there was nothing mentioned about the disciplinary offence alleged to have been committed and the contravened provision.

In this regard, they decline the argument by the employer that absence of charge was immaterial considering that the right to be informed on charges is among tenets of a fair trial constituting a fundamental and basic right under article 13 of the Constitution of the United Republic of Tanzania.

“It is glaring that what is contained in the termination letter and the extract of minutes of the leadership committee on the reasons of termination, is not in the purported charge in which the appellant was initially notified about having proceeded on vacation with the office keys,” the justices said.

They were of the firm position that what was contained in the purported charge, the appellant was not accorded a right to be heard on the nature of accusations as contained in the extract of the minutes of the leadership committee and the termination letter.

In the circumstances, the justices agreed with counsel for the appellant that his client was condemned without being accorded a right to be heard which is a violation of the fundamental and basic right as enshrined under article 13 of the Constitution.

“Furthermore, without prejudice, the employer did not substantiate the allegation on the office being inaccessible on account of the appellant having left with the office keys,” they said.

The justices were fortified in that regard having considered the uncontested appellant's account that the two other keys were held by the Acting Director General and the Head of Department which tells that the office was indeed accessible.

Thus, they said, it could not be safely vouched that the historical collections in the office were destroyed and there was no tangible proof in that regard.

“In a nutshell, in terms of section 110 (1) of the Evidence Act, the (employer) did not discharge the required burden to establish that the appellant had committed a disciplinary offence,” the justices ruled.

The appellant was employed by the National Museum of Tanzania as a Curator History Grade II on September 27, 2005 until her termination on April 30, 2012. She was terminated on accusations of committing several disciplinary offences.

This prompted the appellant to refer the matter to the CMA claiming that the termination was procedurally and substantively unfair and prayed to be paid compensation from the date of termination or reinstatement without loss of remuneration.

The employer denied the allegations, contending that termination was justified because the appellant had breached the disciplinary code and processes and the respective procedures were complied with to the letter.

After a full trial, the arbitrator was satisfied that, the appellant was unfairly terminated both substantively and procedurally in the absence of valid grounds to warrant the termination.

As a result of the said unfair termination, the CMA awarded the appellant reinstatement to the employment without loss of remuneration from the date of termination to date of the award upon payment of a total sum of 59,187,800/-.

 Undaunted, the employer took the matter to the High Court for revision and he was successful and the decision of the CMA was revised. It was at that point in time when the appellant decided to cross the bridge to the Court of Appeal for further scrutiny.

Justice Stella Mugasha.
Justice Ignas Kitusi.
Justice Sam Rumanyika.
Court Hammer.
Court of Appeal building in Dar es Salaam.

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