REB v. LITTLE STEPS LTD

REB v. LITTLE STEPS LTD

The Supreme Court held that Article 93 of Law N° 62/2018 is mandatory and requires termination of a public procurement contract if the winning bidder submitted forged or fraudulently obtained documents, regardless of any subsequent agreement to cure the defect. Since Little Steps Ltd submitted fraudulent guarantees, the contract for Lot 3 and the award for Lot 2 had to be terminated. REB was entitled to recover the advance payment, and Little Steps Ltd was entitled only to the return of its samples, not their value or additional damages.

Citation
RS/INJUST/RCOM 00014/2024/SC
Parties
Applicant: Rwanda Education Board (REB); Respondent: Little Steps Ltd
Court
Supreme Court
Jurisdiction
Rwanda
Judgment Date
23 January 2026
Case Number
RS/INJUST/RCOM 00014/2024/SC
Procedural Posture
Commercial Contract Dispute / Supreme Court Review (revision for Miscarriage of Justice)
Outcome
Appeal allowed; previous judgments overturned; contract terminated for fraud; monetary orders issued.
Legal Topics
Contract Termination, Fraudulent Documents, Advance Payment Guarantee, Performance Guarantee, Public Procurement Procedures
Source Language
rw
Public Procurement Contract Law Contract Termination Fraudulent Documents Advance Payment Guarantee Performance Guarantee Public Procurement Procedures

Case Brief

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Parties

Rwanda Education Board (REB)

Applicant

Little Steps Ltd

Respondent

Procedural Posture

Commercial Contract Dispute / Supreme Court Review (revision for Miscarriage of Justice)

Legal Issues

  1. 1 Whether Article 93 of Law N° 62/2018 on public procurement was disregarded by the High Commercial Court
  2. 2 Whether the contract between REB and Little Steps Ltd should have been terminated due to fraudulent guarantees
  3. 3 Entitlement to return of advance payment and damages

Ratio Decidendi

The Supreme Court held that Article 93 of Law N° 62/2018 is mandatory and requires termination of a public procurement contract if the winning bidder submitted forged or fraudulently obtained documents, regardless of any subsequent agreement to cure the defect. Since Little Steps Ltd submitted fraudulent guarantees, the contract for Lot 3 and the award for Lot 2 had to be terminated. REB was entitled to recover the advance payment, and Little Steps Ltd was entitled only to the return of its samples, not their value or additional damages.

Court Disposition

Appeal allowed; previous judgments overturned; contract terminated for fraud; monetary orders issued.

Orders

  • Little Steps Ltd to return 92,088,294 Frw advance payment to REB
  • Little Steps Ltd to pay REB 1,000,000 Frw in attorney fees