[2] The grounds of the application are set out in the Notice of Motion and in an affidavit sworn in support of the application by James Okori, the Applicant’s head of investigations. Briefly, the grounds are that the Government of Uganda through certain presidential directives, cabinet resolutions, agreements, contracts and statutory instruments has purportedly engaged a Russian company called Joint Stock Company Global Security to execute a compulsory digital surveillance of all motor vehicles, motor cycles and other vessels in Uganda using an electronically activated device to be affixed to the motor vehicle at the owners’ cost to enable government to gather data including location information without the owner’s or user’s knowledge. The Applicant states that although the stated purpose of the surveillance is to help government investigate criminals, parliament and the people were not consulted before it was launched and there are no clear safe guards for protecting the privacy and data of people without connection to criminality and the technology may be used for unauthorized purposes. [3] The Applicant further states that the contracted company lacks the technical and financial capacity to execute a lawful surveillance programme and is neither registered nor certified by Uganda Registration Services Bureau and National Information Technology Authority Uganda to conduct IT business in Uganda. It is also stated that the government breached established Public Procurement Regulations and its obligations to carry out due diligence and neither was a data impact assessment or survey pertaining to global best practices undertaken. As such, the implementation of the programme is in breach of the Respondent’s obligations to respect, uphold and promote the rights to privacy, dignity, good governance and equality of opportunities. The Applicant concludes that the Respondent’s functions will not be crippled if the order of a temporary injunction is issued and the balance of convenience favors the Applicant. On the other hand, if the temporary injunction is not granted, 2