The Industrial Court of Uganda has ordered Matrix Forex Bureau to produce employment and payment records relating to its former employee, Sulaiman Hashil, in a labour dispute that has been before various legal forums for nearly a decade.
In a ruling delivered on June 15, 2026, a panel led by Justice Anthony Wabwire Musana, alongside panelists Adrine Namara, Susan Nabirye and Michael Matovu, directed the foreign exchange company to provide records showing how Hashil was paid between 2013 and October 2016.
The order arose from an application filed by Hashil under Labour Dispute Miscellaneous Application No. 169 of 2024, which stems from Labour Dispute Reference No. 231 of 2016 and KCCA/CEN/LC/280/2016.
Hashil, represented by lawyer Derrick Lutalo of Mwebesa Richard Advocates & Solicitors, sought court orders compelling Matrix Forex Bureau to produce its Daily Count Cash Book used in 2016, original record books, receipts, and bank statements detailing his salary payments from 2013 until his suspension and eventual departure from the company.
According to court records, Hashil argued that despite efforts to obtain the documents, the company had failed to provide them. He maintained that the records were necessary to help establish facts surrounding the dispute and support his claim.
The application proceeded ex parte after the court was satisfied that Matrix Forex Bureau had been duly notified of the proceedings but did not appear. The company is represented by Prof. John Jean Barya of Barya, Byamugisha & Co. Advocates.
In its ruling, the court reaffirmed the legal principles governing applications for discovery of documents, noting that a party seeking disclosure must demonstrate that there is an existing dispute, that the documents are in the possession of the opposing party, and that the documents are relevant to resolving the dispute.
The judges observed that the substantive labour dispute concerns allegations of unlawful suspension, constructive dismissal, unpaid salary, and claims for terminal benefits.
“The original record books, receipts and bank statements showing how the claimant was paid from 2013 would be relevant to the dispute,” the court held.
The court further noted that Uganda’s employment laws require employers to maintain payroll records and provide employees with written particulars relating to their employment and remuneration.
A significant aspect of the ruling involved the court’s discussion on how long employers should be expected to retain employment records.
Justice Musana’s panel acknowledged that Uganda’s labour laws do not expressly prescribe a retention period for employment records. The court reviewed existing legal frameworks, including the Tax Procedures Code Act, which requires records to be kept for five years, and the National Records and Archives Act, which contemplates preservation periods of up to 30 years.
The judges concluded that neither period adequately addresses the realities of employment disputes. They reiterated a position previously adopted by the Industrial Court that employers should reasonably retain employment records for seven years.
According to the court, a seven-year period strikes a balance between employees’ rights to pursue claims and employers’ practical obligations, while aligning with the general six-year limitation period applicable to civil litigation.
“In the absence of explicit statutory direction to the contrary, any demand for the production of employment records dating from over seven years should be considered unreasonable,” the ruling states.
Applying that principle to the case, the court found that records relating to Hashil’s earnings from 2013 to October 2016 fell within a reasonable period and were relevant to determining any entitlement to terminal benefits.
The court consequently ordered Matrix Forex Bureau to produce the requested pay statements, bank records and other documents before the Registrar of the Industrial Court within 21 working days.
No order as to costs was made.
The ruling leaves the main labour dispute pending before the Industrial Court, where the records are expected to play a key role in determining claims relating to alleged unlawful suspension, constructive dismissal and compensation.
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