Wakilii

Arojjo v Stanbic Bank Uganda Ltd & Anor (Miscellaneous Application No. 724 of 2014)

High Court · [2015] UGCOMMC 192 · 2015 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application to be joined as a defendant to originating summons for possession and sale of mortgaged property
Decision
Application to be joined as a defendant dismissed

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The court dismissed the application to join the applicant as a defendant. The applicant sought joinder on the basis that he was in physical possession of mortgaged property as the matrimonial home. The court held that while the outcome might affect the applicant's occupation, he was not privy to the mortgage contract between the bank and the registered proprietor. His presence was not necessary to adjudicate the mortgagee's enforcement rights. Any remedy available to the applicant lay in pursuing his wife, the vendor.

Outcome

Application to be joined as a defendant dismissed

Facts

The applicant, Nickson Arojjo, applied to be joined as a defendant to originating summons brought by Stanbic Bank seeking possession and sale of property comprised in Kyadondo Block 221 Plot 482. The applicant claimed the property was his matrimonial home where he lived with his wife Betty Kirangi and their children. The second respondent, Constance Wakyemba, had borrowed UGX 150,000,000 from the bank and mortgaged the property as security. She was the registered proprietor. The applicant alleged his wife sold the property to the second respondent without his consent, and the second respondent then mortgaged it to the bank. The bank sought to enforce its mortgage rights following default. The applicant was in physical possession of the property and had filed a separate suit challenging the transaction.

Issues

  1. Whether the applicant should be joined as a defendant to Originating Summons No. 1 of 2014.
  2. Whether the applicant's presence is necessary to enable the court to effectually and completely adjudicate upon and settle all questions involved in the suit.

Orders

  • Application dismissed.
  • Costs awarded to the respondent.

Rules and key headnotes

Civil Procedure — Joinder of Parties — Order 1 rule 10 CPR — Test for Joinder
Under Order 1 rule 10(2) of the Civil Procedure Rules, a person may be joined as a party only if their presence before the court is necessary to enable the court to effectually and completely adjudicate upon and settle all questions involved in the suit. The court has no jurisdiction to join a person whose presence is not necessary for that purpose.
Banking & Finance — Mortgage Enforcement — Privity of Contract — Third Party Occupiers
A person in physical possession of mortgaged property who is not a party to the mortgage contract and whose name does not appear on the title is not a necessary party to originating summons brought by a mortgagee to enforce its rights following default by the mortgagor. The mortgagee's enforcement action concerns only the rights and obligations between mortgagor and mortgagee.
Civil Procedure — Joinder of Parties — Separate Remedies — Multiplicity of Suits
Where an applicant seeking joinder has already filed a separate suit to pursue his claimed rights against other parties, the argument that joinder would avoid multiplicity of suits is inapplicable. The applicant should pursue his remedy in the suit he has instituted rather than seek joinder to proceedings to which he is not privy.

Legislation cited (5)

Cases cited (5)

  • Departed Asians Property Custodian Board v Jaffer Brothers Ltd [1991] 1 EA 55
  • Mukuye Steven and 73 Others v Madhivani Group Ltd (Miscellaneous Application No. 821 of 2013)
  • Kato Fred Mazinga v Emmanuel Lukwajju and Others (Miscellaneous Application No. 186 of 2012)
  • Samson Sempasa v P.K Ssengendo (Miscellaneous Application No. 577 of 2013)
  • Amon v Raphael Tuck & Sons Ltd [1956] 1 All ER 273

Full judgment

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

Arojjo v Stanbic Bank Uganda Ltd & Anor (Miscellaneous Application No. 724 of 2014) [2015] UGCommC 192 (8 December 2015)
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.