Wakilii

Equity Bank (U) Limited v Rubahimbya (Civil Appeal 19 of 2023)

High Court · [2024] UGHC 124 · 2024 Appeal Allowed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Appeal from Deputy Registrar's ruling granting temporary injunction without requiring 30% security deposit
Decision
Deputy Registrar's ruling set aside; matter remitted for compliance with Regulation 13(1) deposit requirement

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The High Court held that where a mortgagee has commenced steps to exercise its power of sale under Section 26 of the Mortgage Act by issuing statutory notice, a court order stopping the sale constitutes an adjournment or stoppage under Regulation 13(1) of the Mortgage Regulations 2012, which mandates payment of 30% security deposit. The Deputy Registrar erred in waiving this requirement as the respondent did not fall within the statutory exception for spouses under Regulation 13(6). The injunction granted without enforcing the deposit requirement was improper.

Outcome

Deputy Registrar's ruling set aside; matter remitted for compliance with Regulation 13(1) deposit requirement

Facts

On 27 August 2020, the appellant bank granted the respondent a loan facility of UGX 900,000,000. The respondent defaulted, with outstanding debt of UGX 991,254,129. On 10 January 2023, the appellant issued statutory notice under Section 26 of the Mortgage Act to sell the mortgaged property. On 2 February 2023, the respondent filed suit seeking specific performance. On 6 June 2023, the respondent obtained a temporary injunction restraining sale of the property. The Deputy Registrar granted the injunction without requiring the 30% security deposit stipulated in Regulation 13(1) of the Mortgage Regulations 2012, ruling that the respondent's case fell within provisions allowing waiver of the deposit. The appellant appealed this ruling.

Issues

  1. Whether the Learned Deputy Registrar erred in law and fact when she ruled that the respondent's case falls within the provision of the law where the payment of 30% security deposit can be waived.
  2. Whether the respondent should pay security deposit of 30% of the outstanding amount as a condition for the grant of temporary injunction under Regulation 13(1) of the Mortgage Regulations 2012.

Orders

  • Appeal allowed.
  • The Deputy Registrar's ruling in Miscellaneous Application 25 of 2023 waiving the 30% deposit requirement set aside.
  • Costs of the appeal awarded to the appellant.

Rules and key headnotes

Mortgage — Power of Sale — Stoppage of Sale — Security Deposit Requirement
Where a mortgagee has commenced steps to exercise its power of sale under Section 26 of the Mortgage Act by issuing statutory notice, and a court grants an order stopping the sale, Regulation 13(1) of the Mortgage Regulations 2012 mandates payment of a security deposit of 30% of the forced sale value of the mortgaged property or outstanding amount as a condition for adjournment or stoppage of sale.
Mortgage Enforcement — Temporary Injunction — Statutory Requirements
The remedy of temporary injunction to stop sale of mortgaged property is not available to a mortgagor who has not complied with Regulation 13(1) of the Mortgage Regulations 2012 requiring deposit of 30% of the forced sale value or outstanding amount, once the mortgagee has commenced exercise of its power of sale.
Injunctions — Mortgage Sale — Distinguishing Cases on Spousal Consent
The waiver of the 30% security deposit requirement is distinguishable where the applicant challenges the mortgage on grounds of lack of spousal consent to the mortgage transaction itself, as opposed to cases where the mortgagor merely seeks to stop sale after having validly mortgaged the property and subsequently defaulted.
Mortgage Regulations — Exceptions to Deposit Requirement — Spousal Rights
The exemption from payment of the 30% security deposit under Regulation 13(6) of the Mortgage Regulations 2012 is available only to a spouse, and even then, such spouse must advance reasons why the court's discretion should be exercised to afford exemption from paying the security deposit.

Legislation cited (7)

Cases cited (3)

  • Mutegeki v Mutabazi & 2 Others (Miscellaneous Application No. 109 of 2016)
  • Nakayaga v Fina Bank Ltd & Another (High Court Miscellaneous Application No. 471 of 2014)
  • Ganafa Peter Kisawuzi v DFCU Bank Ltd (Court of Appeal Civil Application No. 64 of 2016)

Full judgment

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

Equity Bank (U) Limited v Rubahimbya (Civil Appeal 19 of 2023) [2024] UGHC 124 (4 April 2024)
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.