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Uganda Judgment

HC: Land Division (Uganda)

Kolya v Nantongo and 2 Others (Misc Cause No. 39 of 2021) [2022] UGHCLD 12 (7 February 2022)

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Source document

01

Holding and result

The court found that the respondents had demonstrated sufficient cause for the caveat to remain in place, specifically citing the existence of a pending appeal as referenced in the notice and application for proceedings. The court held that it would be premature to vacate the caveat at this stage, as maintaining the status quo is necessary to allow the Court of Appeal to resolve the pending appeal without interference. Therefore, the application to vacate the caveat was denied, and each party was ordered to bear its own costs.

Court disposition

application dismissed

Orders

  • The application to vacate the caveat is denied.
  • Each party shall bear its own costs.

02

Material facts

Parties

Daudi Kolya

Applicant

Christine Nantongo

Respondent

Namuddu Marjorie

Respondent Counsel: Muwangadu (represented by Moses Wacha)

Commissioner Land Registration

Respondent

03

Procedural history

  1. Posture

    Miscellaneous Cause / Ruling

04

Questions and positions

Legal issues

Party arguments

Applicant
The applicant seeks the removal of the caveat lodged by the respondents on the basis that the statutory period has lapsed and the respondents have not shown sufficient cause for its retention.
Respondent
The respondents argue that there is a pending appeal and have filed a notice and application for proceedings, thus the caveat should remain to preserve the status quo until the appeal is determined.

05

Court’s reasoning

  1. 01

    Section 140(1) of the Registration of Titles Act

    A caveator must show cause why a caveat should not be removed after the statutory period lapses.

  2. 02

    Judicial precedent and practice

    Retention of the status quo is necessary where there is a pending appeal to prevent prejudice to the appellate process.

06

Ratio, limits and disposition

Ratio decidendi

The court found that the respondents had demonstrated sufficient cause for the caveat to remain in place, specifically citing the existence of a pending appeal as referenced in the notice and application for proceedings. The court held that it would be premature to vacate the caveat at this stage, as maintaining the status quo is necessary to allow the Court of Appeal to resolve the pending appeal without interference. Therefore, the application to vacate the caveat was denied, and each party was ordered to bear its own costs.

Obiter and limits

  • The court noted that the statutory framework requires a caveator to justify the continued existence of a caveat after the statutory period lapses.
  • Premature removal of a caveat in the face of a pending appeal could undermine the appellate process.

Court disposition

application dismissed

  • The application to vacate the caveat is denied.
  • Each party shall bear its own costs.

Source and reliance status

HC: Land Division (Uganda)

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Source document

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Judgment text

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Source document

HC: Land Division (Uganda)

Judgment

[2022] UGHCLD 12

THE REPUBLIC OF UGANDA IN THE HIGH OF UGANDA AT KAMPALA (LAND DIVISION) MISCELLANEOUS CAUSE NO. 0039 OF 2021

DAUDI KOLYA:::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::APPLICANT

VERSUS

1. CHRISTINE NANTONGO

2. NAMUDDU MARJORIE

3. COMMISSIONER LAND REGISTRATION:::::::::::::::RESPONDENTS

BEFORE: HON MR. JUSTICE HENRY I. KAWESA

RULING

This is an application by way of Notice of Motion for orders that;

1. A caveat lodged by the Respondents vide Instrument No. KCCA-U007-0074090 on land comprised in Block 244 Plot 5198 Kisugu be vacated.

The application is opposed by the affidavit in reply of Marjorie Namuddu.

I have looked at the submissions. Under Section 140(1) of the Registration of Titles Act, the law requires that once a caveator files a caveat, the caveator has to show cause why the caveat should not be removed after the statutory period lapses.

In this particular case, the caveator has shown cause that there is a pending appeal as per the notice and application for proceedings referred to by the Respondents. This Court is satisfied that it is premature to vacate the caveate as it is necessary to retain the *status* quo to enable the Court of Appeal to first settle the appeal.

1 st Defendant pleaded in paragraph 3 of the written statement of defence that they would raise a preliminary objection on the competency of the suit, hence this application.

I do find merit in the application.

It is allowed.

Each party should bear its own costs.

I so order.

Henry I. Kawesa JUDGE 07/02/2022

......................................

07/02/2022:

Moses Wacha holding brief for Muwangadu for the Respondent.

Applicant in Court.

Respondent absent.

Counsel for Applicant absent.

Lydia: Court Clerk.

Moses: it is for Ruling.

Court:

Ruling read out in court in the presence of the parties present.

Sgd:

Ayo Miriam Okello

DEPUTY REGISTRAR

07/02/2022

Source wording is retained. Consult the source document for its original formatting and pagination.

Authorities

Authorities used by the court

Cases, legislation, regulations, and constitutional provisions identified in the available record.

Section 140(1) Registration of Titles Act

Legislation

Legislation referenced in the available case record.

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