BAT v. Executive Branch

British American Tobacco (BAT) challenged an executive decree requiring plain packaging of tobacco products. While an administrative tribunal (Tribunal de lo Contencioso Administrativo) is considering the initial challenge, BAT also filed a rapid constitutional challenge, called an “amparo,” requesting suspension of the decree until the administrative challenge is decided (which may take up to one year). With regard to the amparo, the Administrative First Instance Court decided in favor of BAT because the plain packaging policy was approved through a decree instead of a law passed by Congress.

Here, the government appealed the decision by the Administrative First Instance Court, and the Court of Appeals ruled in favor of the government. The Court of Appeals found that the amparo was not the proper mechanism for the challenge, because there is a pending administrative claim. This decision was final, and BAT cannot appeal the decision. The decision does not address the merits as to whether the policy is constitutional, only that the President did not have the power to enact the policy by way of executive order.

British American Tobacco Ltd v. State - Executive Power – AMPARO, Fa.2-37586, Tribunal de Apelaciones en lo civil [Appeals Court] (2018).

  • Uruguay
  • Oct 11, 2018
  • Civil Court of Appeals, Sixth Turn.
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Parties

Plaintiff British American Tobacco Limited

Defendant State - Executive Branch

Legislation Cited

Articles 261 and 56 of the General Code of Procedure

Constitution of Uruguay

Law No. 16011

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

None

Type of Tobacco Product

None

"It should be noted that the plaintiff requested the suspension of the act by way of amparo, when the deadline for the resolution of the administrative appeal of revocation that she deduced against her last August 27 is running (fs. 7 and 8). The plaintiff also requested the suspension of the execution of the decree, which will be applicable as of February 6, 2019, so this way is suspending an administrative act that is not being executed, without giving the opportunity for the Executive for the sake of proper administration, to review its decision. In turn, once the time limit has expired or the appeal has been resolved, the plaintiff will have an action for nullity in the event that the administrative decision is upheld, and may, at that time, request the suspension of the act in accordance with articles 2 and 3 of Law No. 15869.In this regard, the Chamber has held: "For these reasons, it cannot be said that the means are not effective in protecting the rights allegedly violated, because they were not directly attempted. It must be borne in mind that art. 2 of Law No. 16011 refers to the fact that the means for the protection of the right must be "clearly ineffective" and no less effective than the measure sought through the means of amparo", (cf. sentences Nos. 166/06, 123/08 and 105/2017 of the Court).The delay in the processing of jurisdictional or administrative means is not synonymous with inefficiency, so it is not possible to mechanically assimilate the mere delay to the clear inefficiency required by law to make the mechanism of amparo appropriate (RUDP No. 3/97, c. 501, p. 385)."