The appellant, Midlands State University (a tertiary institution established by statute), engaged the respondent, Galaxy Engineering Design Consultants, to design civil and engineering works for construction of buildings and Master Site Services at its main campus in Gweru on 3 September 2003. The parties concluded seven contracts, four of which were in dispute: Faculty of Commerce and Information Systems/Law and Administration, Faculty of Architecture/Art and Design, Vice Chancellor's House, and Master Site Service Design. On 14 June 2005 and 5 August 2005, the appellant instructed the respondent to stop all work. A dispute arose as to whether the respondent had completed its contractual obligations at the time of cessation and what payment was due. The parties had introduced an addendum containing clause 4.1, which provided that the appellant, being publicly funded, would hold invoices in abeyance until the Government of Zimbabwe allocated funds. The appellant paid US$84,827.17 without interest. On 16 July 2015, the respondent sued for US$3,292,277.90 plus interest at 19.5% per annum from 1 November 2010.