GRA fights GH¢79.65m Servestar judgment debt — commends director for rejecting excess award

The Ghana Revenue Authority (GRA) has launched an appeal against a GH¢79.65 million judgment debt awarded to Servestar Minwax (WA) Limited, arguing that the amount requires urgent forensic reconciliation before any payment is made from public funds.

The extraordinary dispute has taken another twist after Servestar director Henry Manly-Spain reportedly told the GRA that the amount he considers legitimately due to his company is significantly lower than the GH¢79.65 million awarded by the court. The GRA has praised him for what it described as exceptional honesty, integrity and patriotism.

From less than GH¢1m to GH¢79.65m

At the heart of the dispute is a case dating back to 2009, when Servestar Minwax claimed it had overpaid import duties by an amount of less than GH¢1 million.

The company subsequently pursued the matter through the courts and obtained judgment in its favour.

However, the amount now being enforced has grown dramatically to GH¢79,651,132, with the GRA attributing a significant portion of the increase to the application of 35% daily compound interest.

The massive difference between the original dispute and the current judgment sum has become the central point of the GRA’s challenge.

High Court orders payment from GRA account

On July 22, 2026, the High Court’s Commercial Division 3 issued a Garnishee Order directing the Bank of Ghana to release GH¢79.65 million from the GRA’s Tax Refund Account to Servestar Minwax and its director, Henry Manly-Spain.

But the GRA has strongly contested the amount and the manner in which the funds were to be obtained.

The Authority has filed a Notice of Appeal against the entirety of the High Court’s ruling and has also applied to have the Garnishee Order Absolute set aside.

GRA demands forensic reconciliation

The revenue authority wants an independent examination of the judgment debt before any money is released.

The High Court on August 20, 2026, granted the GRA’s request for a forensic reconciliation and allowed an independent auditor to review the amount being claimed.

The GRA says the exercise is necessary to determine the accurate amount legitimately owed and resolve what it considers material discrepancies in the certified judgment debt.

The Commissioner-General has also ordered an internal audit of the reconciliation and litigation processes surrounding the case to determine whether any lapses occurred and strengthen the Authority’s internal controls.

The unusual twist: beneficiary rejects the money

Perhaps the most striking development is the position taken by Henry Manly-Spain himself.

According to the GRA, documents submitted through his solicitor indicate that the amount he believes is legitimately due for overpaid duties and the value of containers sold since 2009 is far below the GH¢79.65 million judgment sum.

Earlier reports quoted Manly-Spain as saying his company’s legitimate claim was about GH¢8.95 million, although the GRA’s latest statement describes his position more generally as being significantly lower than the court-awarded amount.

That unusual position has prompted the GRA to publicly commend him.

‘Exceptional honesty, integrity and patriotism’

The GRA described Manly-Spain’s decision to question the amount awarded to his own company as an extraordinary act of honesty.

The Authority said it had received his petition asking that the judgment amount not be disbursed, and that his position had been formally brought before the court as part of the proceedings to set aside the garnishee order and reconcile the debt.

The development has added an unusual dimension to what began as a conventional dispute between a taxpayer and the revenue authority.

GRA challenges attachment of Tax Refund Account

The Authority is also challenging the attachment of the account from which the payment was ordered.

The GRA maintains that its Tax Refund Account at the Bank of Ghana is statutorily protected under Section 69 of the Revenue Administration Act, 2016 (Act 915) and is specifically intended to facilitate legitimate refunds to taxpayers who have overpaid taxes.

It therefore argues that the account should not be attached in the manner directed by the High Court.

Stay of execution battle continues

The GRA said its earlier application for a stay of execution was unsuccessful.

However, it intends to renew its application before the Court of Appeal at the commencement of the new legal year.

The Authority insists that its legal action is aimed at protecting public funds while still respecting lawful court decisions.

“The GRA will not permit unvalidated judgment debts to be paid from tax revenue,” the Authority said.

A judgment debt now under intense scrutiny

The Servestar case has therefore moved into a new phase.

On one side is a court order directing the payment of GH¢79.65 million. On the other is the GRA’s appeal, its demand for forensic reconciliation, an internal audit and the extraordinary position of the beneficiary himself that the amount awarded is significantly higher than what he believes is legitimately due.

For now, the money remains at the centre of a legal and financial battle that could have significant implications for the public purse.

What began in 2009 as a dispute involving less than GH¢1 million has now grown into a GH¢79.65 million judgment-debt controversy — with even the man entitled to the award questioning whether the staggering figure is truly his to take.