Ddamulira Laddisirawo v Commissioner Land Registration and Another (Miscellaneous Cause No. 07 of 2022)
Observed later treatment
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Holding
The High Court held that beneficiaries listed in Buganda Succession Registers possess locus standi to claim their shares without further administration. Where the Local Administrations (Performance of Functions) Instrument S.I. No. 150 of 1967 has been deleted, creating a regulatory vacuum, the court may exercise inherent jurisdiction under sections 33 of the Judicature Act and 98 of the Civil Procedure Act to order creation of a certificate of title and transfer of land to a beneficiary named in a Succession Register, to prevent injustice and give effect to vested proprietary rights.
Outcome
Application allowed. 1st Respondent directed to create certificate of title and, upon submission of location survey report and satisfaction that no third-party interests are prejudiced, to mutate and transfer 35 acres to the Applicant as his beneficial share from the estate.
Facts
The late Alege Musoke died on 21 February 1958 leaving a will detailing distribution of his estate, including approximately 60.73 acres of Mailo land registered as Vol. 525 Folio 7 Mawokota Block 313 Plot 12 at Kawumba Village, Mpigi District. The distribution was recorded in Succession Register Book No. SR/15/1828, which named the Applicant, Ddamulira Laddisirawo, as heir and bequeathed him 35 acres from the land. The Kasimba Clan conducted succession proceedings on 13 July 1961 and forwarded the record to the Lukiiko and Kabaka for assent in accordance with the Buganda Succession Law of 1912. The Applicant repeatedly approached the Administrator General to facilitate transfer of his share but received no response. The Applicant then filed this application seeking orders for creation of a certificate of title and transfer of his 35-acre beneficial share. The 1st Respondent did not dispute the Applicant's beneficial interest but raised procedural concerns regarding land availability, third-party interests, and the need for a location survey report. The 2nd Respondent did not file a response.
Issues
- Whether the Applicant has established sufficient grounds to warrant the creation of a white page (certificate of title) for Mawokota Block 313 Plot 12 at Kawumba.
- Whether the Applicant is entitled to an order directing the mutation and transfer of 35 acres from the said land into his names as his beneficial share from the estate of the late Alege Musoke.
- Whether the Applicant is entitled to costs of this application.
Orders
- The 1st Respondent is directed to create a white page (Certificate of Title) for land comprised in Vol. 525 Folio 7 Mawokota Block 313 Plot 12 situated at Kawumba Village, Musale Sub-County, Mawokota County, Mpigi District.
- The Applicant shall procure and submit a location survey report to the 1st Respondent confirming the land's boundaries, availability, and absence of third-party claims or overlapping titles in respect of the said land.
- Upon compliance with Orders 1 and 2 and upon the 1st Respondent's satisfaction that no third-party interests are prejudiced, the 1st Respondent shall at the Applicant's cost, mutate and transfer 35 acres from the said land into the Applicant's name, as his beneficial share from the estate of the late Alege Musoke, in accordance with the binding distribution in Succession Register No. SR/15/1828.
- The 2nd Respondent shall cooperate with the 1st Respondent by availing any relevant estate records or documentation necessary to facilitate compliance with the above, notwithstanding the limits on its jurisdiction over such estates.
- No order as to costs.
Rules and key headnotes
Legislation cited (7)
- Judicature Act Cap. 16 s.33
- Civil Procedure Act Cap. 282 s.98
- Civil Procedure Act Cap. 282 s.27
- Civil Procedure Rules S.I. 71-1 Order 52 rules 1, 2, and 3
- Civil Procedure Rules S.I. 71-1 Order 15 rule 1(5)
- Kingdom of Buganda Succession Law of 1912
- Local Administrations (Performance of Functions) Instrument S.I. No. 150 of 1967
Cases cited (7)
- Nagaddya Winfred & Another v Administrator General (Civil Suit No. 0045 of 2021)
- Paulo Kawesa v Administrator General and 2 Others (Civil Suit No. 918 of 1993)
- Namubiru Oliver Nakityo & Another v Administrator General (Miscellaneous Application No. 1726 of 2024)
- Grobbelaar v. News Group Newspapers Ltd. [2002] 1 WLR 3024 at 3037B
- MC v MJ (A3076/2016) [2017] ZAGPJHC 279 (28 March 2017)
- Ex parte Millsite Investments Co (Pty) Ltd
- Good African Foundation Ltd & Another v Agricultural Business Initiative Trust (Miscellaneous Application No. 1592 of 2021)
Cases citing this judgment (1)
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
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