Former Insurance Regulatory Authority (IRA) chief executive Ibrahim Lubega Kaddunabbi has gone to the High Court seeking to quash an Auditor General’s investigation report that reinforced the IRA board’s decision not to recommend him for another five-year term.
In a judicial review application before the High Court’s Civil Division, Kaddunabbi is challenging the legality, rationality and procedure behind the May 15 report on alleged financial and administrative impropriety at IRA.
He wants court to issue certiorari quashing decisions contained in the report and to restrain government agencies from acting on it. He is also seeking damages and costs.
Kaddunabbi’s term as IRA chief executive ran from June 2021 to May 31, 2026. He applied to the IRA board in May 2025 for a recommendation to the Finance Minister for another term, but the board declined to recommend him. He separately challenged that decision in court.
The dispute widened after Permanent Secretary and Secretary to the Treasury Ramathan Ggoobi wrote to the Auditor General on March 19, 2026, asking for a comprehensive review of allegations contained in a communication by the IRA board chairperson.
The request was accompanied by internal audit reports raising concerns over spending and recruitment practices, upon which, acting under Article 163 of the Constitution and Section 21 of the National Audit Act, the Auditor General constituted a special audit team to confirm or dispel the allegations.
Kaddunabbi, however, argues that Ggoobi had no authority under the Insurance Act to direct such an investigation and that the Auditor General exceeded his mandate by accepting and executing the assignment.
In his affidavit, he describes the resulting decisions as “illegal, irrational and marred with procedural impropriety”.
His case is especially significant because the IRA board later considered the Auditor General’s findings and maintained its earlier position not to recommend him to the minister.
Kaddunabbi says he is aggrieved because IRA’s board relied on the said report to maintain their earlier recommendation to the Minister declining to recommend him for a further term as IRA chief executive officer.
The Auditor General’s report made several adverse findings such as increase of Kaddunabbi’s salary outside guidelines, illegal recruitment of staff and irregular per diem payments.
The Auditor General found that Kaddunabbi’s pay had been increased above the level approved by the Finance Minister between 2021 and 2025.
Although the increments were reflected in budgets approved by the IRA board, the report concluded that they did not follow the minister’s guidance on inflation-based adjustments and had not been recommended to the minister for approval.
The report says Kaddunabbi’s instrument of appointment fixed his gross consolidated monthly salary at Shs45.34m.
After he requested an increase to Shs55m, the minister declined, saying only a limited inflation adjustment based on Central Bank data could be considered after a board recommendation.
Kaddunabbi disputes the Auditor General’s approach, arguing that the audit relied on “mere inflation” and failed to consider the broader inflation picture or the fact that IRA board had approved annual budgets containing salary increments.
The investigation also questioned leave-related payments, in which it found that Kaddunabbi irregularly received Shs38.1gh in lieu of leave, despite there being no evidence that he had taken the corresponding leave.
It also questioned Shs87.17m paid as compensation for untaken leave relating to his 2016-2021 contract.
The report records Kaddunabbi’s explanation that he approved the leave allowance because he had not previously been paid it and understood the benefit to be additional income provided to employees while on leave.
He now argues that the audit improperly examined earlier contracts instead of focusing on the 2021-2026 contract relevant to his reappointment.
Another major issue concerns his travels as a director of African Reinsurance Corporation, or Africa Re.
The Auditor General found that Kaddunabbi received Shs16.97m from IRA as per diem for Africa Re activities, although his Africa Re contract provided that expenses related to board meetings were to be met by the company.
The report concluded that IRA should only have paid 30 percent per diem for fully sponsored activities and estimated that full per diem payments for five Africa Re activities caused a financial loss of Shs57.43m.
But the report also acknowledges limitations, noting that investigators sought information from Africa Re on benefits payable to Kaddunabbi as a director, but that information had not been provided by the time the report was completed.
It further states that the investigation was limited to documents and information made available and that the Auditor General had “not verified the authenticity” of relevant records except in specifically identified instances.
Kaddunabbi has seized on that disclaimer, arguing in his affidavit that the Auditor General relied on documents and information whose authenticity had not been verified.
The Auditor General’s report also faulted Kaddunabbi for authorising and participating in the hiring of six additional employees beyond the number advertised. Although the report acknowledged that the board had given general approval for more recruitment following a restructuring exercise, it said the specific extra hires had not been discussed or documented before implementation.
An earlier internal audit estimated that six hires lacking approval and documentation created about Shs647.55m in unplanned salary and benefit costs over 12 months.
Kaddunabbi disputes that conclusion, saying the board had approved a staffing establishment of 106 positions and that the recruitment remained within the approved structure.
Beyond the substance of the findings, Kaddunabbi also attacks the procedure followed by the Auditor General, saying that investigators had interviewed only one of the eight board members involved in relevant decisions and alleges that he was not given a proper opportunity to answer the accusations before the report was finalised.
“The [Auditor General] did not accord me a fair hearing during preparation and completion of its report and accepted all accusations made against me without affording me a right to respond,” he states in his affidavit.
Kaddunabbi argues that the report, however, went far beyond the purpose it had been requested for, entered the public domain, damaged his reputation, influenced the board against his reappointment and exposed him to possible criminal investigations.