The Insurance Regulatory Authority (IRA) has defended its decision not to recommend the renewal of former Chief Executive Officer Alhaj Kaddunabbi Ibrahim Lubega’s contract, arguing that his case has been overtaken by events following the expiry of his contract.
In affidavits filed before the Civil Division of the High Court in response to Mr Kaddunabbi’s application on Monday, the Authority and its former Board chairman, Dr. Isaac Nkote Nabeta, contend that there is no longer any contract for the court to preserve, maintain, or reinstate because Kaddunabbi’s five-year term expired on May 31, 2026.
Through their lawyers of Denton Advocates led by Counsel John Musiime, IRA and Dr Nkote further argue that the Minister of Finance, Planning and Economic Development has since appointed Protazio Sande as Acting Chief Executive Officer effective today, June 1, 2026, making the interim relief sought by Kaddunabbi legally untenable.
According to Francesca N. Kakooza, the Secretary to the Board of the Insurance Regulatory Authority, Mr Kaddunabbi’s employment contract was strictly for a fixed term running from June 1, 2021, to May 31, 2026, and naturally came to an end by operation of law.
Kakooza states that ahead of the contract’s expiry, the current Board Chairperson, Mr Keto Nyapendi Kayemba, directed Mr Kaddunabbi on April 29, 2026, to proceed on outstanding leave and complete a handover process to ensure continuity at the regulator.
The Authority says the handover process has already been concluded and that Protazio has assumed office as Acting Chief Executive Officer.
IRA officials argue that granting Mr Kaddunabbi’s application would create an absurd situation in which two individuals simultaneously claim authority as Chief Executive Officer of the same statutory body.
According to the affidavits, such a development would disrupt governance structures, create uncertainty over control of public resources, and undermine the operations of Uganda’s insurance regulator.
The dispute stems from a decision taken by the IRA Board on February 16, 2026, declining to recommend Kaddunabbi to the Minister of Finance for reappointment as Chief Executive Officer for a second five-year term.
The Authority further stated that the Board’s deliberations were informed by findings from internal reviews and audits, which raised concerns about governance and financial management.
Mr Kaddunabbi subsequently filed a judicial review application challenging the decision and seeking declarations that the Board acted illegally, irrationally and unfairly. He also wants the court to quash the decision and restrain the Authority from implementing it.
In his application, Mr Kaddunabbi argues that he was denied a fair hearing before the Board made its decision, despite having consistently received outstanding performance ratings and meeting all requirements for reappointment.
The outgoing Chief Executive Officer maintains that he had a legitimate expectation to be considered fairly for another term after serving the Authority for over a decade.
Records before the Court indicate that Mr Kaddunabbi formally expressed interest in the renewal of his contract on May 28, 2025, in accordance with the Authority’s Human Resource Management Manual and the Insurance Act.
He submitted reports showing his achievements registered during his tenure, including growth in insurance industry premiums, increased claims settlements, expansion of regional operations, construction of Insurance Tower, automation of regulatory functions, and implementation of sector reforms.
Mr Kaddunabbi argues that his performance had consistently been rated highly by the Board and that he was therefore eligible and suitable for reappointment. However, the Authority argues that eligibility for consideration did not translate into an automatic right to another term.
Court records show that Mr Kaddunabbi joined the regulator in 2011 as Chief Executive Officer of the then Uganda Insurance Commission before it evolved into the Insurance Regulatory Authority. Following amendments to the Insurance Act in 2017 introducing term limits for chief executives, he was appointed under the new legal framework for a five-year term beginning in June 2021.
He has so far served a combined total of 16 years as the Chief Executive Officer.
On Monday, IRA’s lawyers at Dentons wrote a letter to Mr Kaddunabbi’s lawyers at Arcadia Advocates, cautioning him not to illegally appear at the institution.
‘Our client (IRA) informs us that this morning (Monday morning), your client (Mr Kaddunabbi) Ibrahim Lubega entered the premises of IRA, convened an authorized assembly of staff members, and formally asserted that he remains the Chief Executive Officer of the Authority. This conduct was falsely presented to staff as being authorized and protected by an administrative interim order issued by Her Lordship Justice Joyce Kavuma on May 29th,’ IRA’s lawyers at Dentons wrote.
Adding, ‘According to the administrative interim order, neither renewed nor extended your client’s contract of employment beyond its expiry on 31st May, nor did the court appoint your client as Chief Executive Officer. Furthermore, the court did not confer upon him any authority to continue exercising the powers and functions of that office after expiry of his contract, or did it invalidate or suspend the exercise of a lawful statutory power by the appointing authority following the expiry of your client’s contract.’
Going forward, IRA’s lawyers don’t want to see Mr Kaddunabbi access the institution.
‘Accordingly, we hereby demand that your client immediately cease and desist from entering the premises of the Authority under the color of office, masquerading as the Chief Executive Officer, or interfering in any manner whatsoever with the administration, staff, or operations of the Authority.’ the lawyers wrote.
The respondents also argued that any loss Mr Kaddunabbi may suffer can adequately be compensated through damages should he ultimately succeed in court. They contend that he has failed to demonstrate irreparable harm warranting the grant of interim judicial remedies.
Consequently, IRA officials have asked the High Court to dismiss the applications with costs.
The matter came up for hearing on Monday before the Civil Division of the High Court in Kampala.
Presiding judge Joyce Kavuma directed Mr Kaddunabbi’s lawyers to file their written submissions by June 5, 2026, while IRA lawyers were ordered to file their submissions by June 10.
Justice Kavuma further directed the parties to return to court on June 12, when she is expected to issue further directions on the management and progression of the case.