Wakilii

Ali Ssenyonga v Letshego Uganda Limited and Another (Civil Suit No. 24 of 2020)

High Court · [2025] UGHC 1100 · 2025 Judgment for Plaintiff — Sale Cancelled AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
First instance civil suit for recovery of mortgaged property and challenge to mortgage sale
Decision
Sale agreements cancelled and second defendant's entry on certificate of title cancelled

Observed later treatment

No later-treatment classification is recorded for this judgment.

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AI-generated summary. This summary was generated by AI from the full text of the judgment. It may contain errors or omissions—always read the source judgment before relying on it.

Holding

The court found that although the plaintiff breached the loan agreement and the interest rates imposed were lawful, the sale of the mortgaged property by the first defendant to the second defendant was unlawful and irregular. The sale relied on an expired valuation report in contravention of the Mortgage Regulations 2012 which require a valuation not older than six months. The defendants also failed to serve default notices and notice of intended sale on the sureties as required by the Mortgage Act. The transfer to the second defendant violated ministerial directives halting land transfers during the COVID-19 lockdown. The court cancelled the sale agreements and the second defendant's entry on the certificate of title.

Outcome

Sale agreements cancelled and second defendant's entry on certificate of title cancelled

Facts

The plaintiff obtained a loan of UGX 40,000,000 from the first defendant and mortgaged two properties as security, including FRV MSK 105 Folio 11 owned by Hajji Issa Ssenyonga. The plaintiff claimed he serviced the loan but the first defendant sold one mortgaged property alleging default. On 28 May 2019, the plaintiff requested a two-month grace period to clear outstanding loan money. The property was valued on 31 July 2019 at UGX 23,000,000 forced sale value. The first defendant sold the property to the second defendant on 10 February 2020. The second defendant was registered on the title during the COVID-19 lockdown period when the Minister of Lands had issued directives halting land transfers. The sureties, including the registered owner Hajji Issa Ssenyonga, were not served with default notices or notice of intended sale.

Issues

  1. Whether the Plaintiff breached the loan agreement?
  2. Whether the interest imposed on the loan facility was harsh and unconscionable?
  3. Whether the sale of the mortgaged property for land comprised in FRV MSK 105 Folio 11 Buddu Block 360 Plot 120, situate at Kaboyo by the 1st Defendant to the 2nd Defendant was lawful?
  4. Whether the entry of the name of the 2nd Defendant into the certificate of title of the sold mortgaged property was lawful?
  5. What remedies are available to the parties?

Orders

  • The Defendants' agreements of sale of Hajji Isa Ssenyonga's land comprised in FRV MSK 105 Folio 11 Plot 120 are cancelled.
  • The entry of the 2nd Defendant onto the certificate of title to FRV MSK 105 Folio 11 Plot 120 at Kaboyo is hereby cancelled.
  • Each party will bear its own costs of the suit.
  • Judgment is largely entered for the Plaintiffs and against the Defendants.

Rules and key headnotes

Loan Agreements — Breach — Grace Period Request as Admission
A borrower's written request for a grace period beyond the agreed repayment period constitutes an admission that the borrower breached the loan agreement.
Interest Rates — Contractual Interest — Retrospective Application of Legislation
Interest rates lawful under the Money Lenders Act Cap. 273 at the time of contract execution remain valid and contractual. The Tier 4 Microfinance and Money Lenders Act 2016, which came into force in 2017, has no retrospective effect on contracts executed in 2015.
Mortgage Sales — Valuation Requirements — Validity Period
Under Regulation 11(1) and 12 of the Mortgage Regulations 2012, a sale of mortgaged property must depend on a valuation report made not more than six months before the sale. A sale transacted outside this six-month window is unlawful and irregular.
Mortgage Sales — Notice to Sureties and Guarantors — Mandatory Requirement
Section 25(3)(c) of the Mortgage Act Cap. 239 requires that notice of intended sale be served on sureties and guarantors. The purpose of this requirement is to afford them an opportunity to redeem the mortgaged property from sale. Failure to serve such notice renders the sale unlawful.
Land Transfers — Ministerial Directives — COVID-19 Restrictions
Land transfers effected during the period when the Minister of Lands had issued directives halting all transfers during the COVID-19 nationwide lockdown are illegal and in contravention of ministerial directives, regardless of whether a Registrar of Titles was moved to effect the transfer.
Mortgage Sales — Due Diligence — Duty of Purchaser
Where mortgaged property does not belong to the debtor but to a known surety, a purchaser's due diligence should include direct inquiry with the registered owner as to the lawfulness of the sale, not merely reliance on information from the vendor's agents.

Legislation cited (8)

Cases cited (4)

  • George William Kakoma v Attorney General [2010] HCB 1
  • Sebuliba v Cooperative Bank Ltd [1982] HCB 130
  • Oketha v Attorney General (Civil Suit No. 69 of 2004)
  • Fredrick J.K Zaabwe v Orient Bank Ltd and Others (SCCA No. 4 of 2006)

Full judgment

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The original judgment as reported. Read the original PDF before relying on any passage.

Ali Ssenyonga v Letshego Uganda Limited and Another (Civil Suit No. 24 of 2020) [2025] UGHC 1100 (3 February 2025)
Source: this page presents Wakilii’s issue analysis and metadata for a publicly reported Ugandan judgment. Any AI-generated summary is marked as such. Judgment text is sourced from the Uganda Legal Information Institute (ulii.org). Wakilii is not affiliated with ULII.