Damanico Properties Limited v Major General Muheesi (Civil Suit 45 of 2016)
Observed later treatment
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Holding
Held that a registered proprietor who has never taken actual or constructive possession of land cannot maintain an action for trespass against a defendant who acquired interests from bibanja owners and lawful occupants in continuous occupation since the 1970s. The Land Act's protection of bonafide and lawful occupants takes precedence over common law trespass claims where the registered proprietor made no attempt to assert ownership or notify occupants of their interest for over a decade after registration.
Outcome
Both the plaintiff's suit and the defendant's counterclaim dismissed; defendant entitled to remain in occupation
Facts
Plaintiff company was registered as proprietor of FRV 63 Folio 1 in May 1998 after purchasing land from Khimchand K Shah Limited, which had repossessed the land after the expulsion of Asians in 1972. Plaintiff claimed land was vacant at acquisition and that they appointed managers to supervise it. In 2009, plaintiff discovered defendant and workers clearing, cultivating, and constructing structures on the land. Defendant claimed he purchased bibanja interests from multiple occupants who had been on the land since the 1970s. Evidence showed land had been continuously occupied by various persons cultivating bibanja portions. Plaintiff attempted to open boundaries in 2008 (ten years after registration) and encountered existing occupants. Defendant acquired interests from these occupants beginning in 2008 and established coffee plantation covering the entire piece of land.
Issues
- Whether the defendant/counterclaimant is a trespasser to the suit land comprised in FRV 63, Folio 1, situate at Kabulamulilo in Kiboga and Mityana Districts.
- Whether the plaintiff/counter-defendant obtained registration as proprietor to the suit land comprised in FRV 63, Folio 1, situate at Kabulamulilo in Kiboga and Mityana Districts illegally and/or fraudulently.
- What remedies are available to the parties?
Orders
- The plaintiff's claim dismissed.
- The defendant is not a trespasser on the said land.
- No order as to costs.
- The defendant/counterclaimant's counterclaim dismissed.
- The plaintiff was lawfully registered as a registered proprietor of the suit land.
- No order as to costs on the counterclaim.
Rules and key headnotes
Legislation cited (5)
Cases cited (2)
- Asuman Mugenyi v M Buwule (Supreme Court Civil Appeal No. 14 of 2016)
- Adesina v Ojo (2012) 10 NWLR p.552
Cases citing this judgment (3)
How later Ugandan judgments in the Wakilii corpus have cited this case. Treatment labels come from Sequitur — Uganda’s citator — each backed by a verbatim span from the citing judgment, and are not an assertion that this case is, or is not, good law.
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.