URA officer wins Shs100m over defamatory WhatsApp messages

• Shs100m damages: Nicholas Jjengo wins Shs70 million in general damages and Shs30 million in punitive damages.

• WhatsApp defamation: James Abola linked Jjengo to a shooting and alleged dispute over a woman in a URA management group.

• Failure to verify: Court finds Abola circulated sensational allegations despite having an opportunity to verify them.

• Apology ordered: Abola must apologise on the URA Senior Management WhatsApp forum and is barred from repeating the defamatory claims.

The High Court in Kampala has awarded Uganda Revenue Authority (URA) officer Nicholas Jjengo Shs100 million after finding that a senior colleague defamed him in a management WhatsApp group.

Justice Isaac Bonny Teko ruled that James Abola defamed Jjengo through messages posted on the URA Senior Management WhatsApp forum on September 18, 2022. The messages linked Jjengo to a shooting and suggested the incident arose from a dispute over a woman.

In a judgment delivered on June 17, 2026, Teko awarded Jjengo Shs70 million in general damages and Shs30 million in punitive damages. He also ordered Abola to apologise on the same WhatsApp forum within 14 days.

Jjengo sued Abola for libel after the latter posted messages claiming that police in Kasangati were looking for him over a shooting.

The first message said police were looking for Jjengo, a customs officer, who had allegedly fired three bullets at victims the previous night.

A second message alleged that the "perpetrator" followed another person's car and shot at it near the victim's gate in Magere. It claimed the group had earlier gone for an outing and that a woman, described as a "skirt", had refused to enter the alleged perpetrator's car and instead joined the victim.

The court found that the messages portrayed Jjengo as a criminal, violent and immoral person.

Teko said the use of the word "skirt" introduced a sexual and moral innuendo. It portrayed Jjengo, a married man and public officer, as immoral, reckless and unfit for trust.

Abola denied liability. He told court that he received the information from ASP Patrick Lumumba Okello, an officer attached to the Staff Compliance Division. He argued that he shared it in good faith and as part of his duties.

He also argued that the WhatsApp group was restricted to URA senior managers and that he had stated that the claims were allegations and investigations were continuing.

The court accepted that Abola, as Assistant Commissioner Staff Compliance, had a legitimate duty to alert management about serious allegations against a URA employee. It therefore found that the communication initially qualified for legal protection under qualified privilege.

However, Teko ruled that Abola lost that protection when he circulated an unverified and sensational account of the incident.

The judge noted that James Malinzi, Jjengo's head of division, contacted Jjengo and was told that the account was wrong. According to Jjengo, his wife and child had instead been attacked at their home.

Malinzi also gave Abola Jjengo's telephone number and asked him to verify the information. The court found no credible evidence that Abola made meaningful attempts to verify the claims before or after publishing the second message.

Teko said stating that information was an allegation did not shield Abola from liability.

"A person who republishes defamatory allegations cannot escape liability merely by saying that the matter is alleged," the judge said.

The court found that Abola knew investigations were incomplete but still published a dramatic account involving criminality, violence and sexual impropriety. It also noted that he did not issue a correction or apology after being asked to verify the information.

The judge ruled that this amounted to reckless disregard for Jjengo's reputation and was enough to establish malice in law.

Abola had argued that Jjengo suffered no actual damage because URA did not discipline or demote him. Jjengo was later confirmed or promoted as a supervisor.

The court said this could reduce the damages but did not erase the defamation. It also considered that the messages were confined to a restricted management forum rather than published to the general public.

Teko awarded Jjengo Shs70 million in general damages. He added Shs30 million in punitive damages to show the court's disapproval of Abola's reckless use of a privileged management platform.

The court also permanently barred Abola from repeating the same or substantially similar defamatory allegations unless any future communication is lawful, made in good faith, properly verified and within his official mandate. Jjengo was also awarded the costs of the suit.