Foods & Verages Limited v Musisi (Civil Appeal 32 of 1992)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The Supreme Court considered whether a party that seized and retained another's lorry under an honest but mistaken claim of right was liable when the vehicle was cannibalised in its custody, and whether failure to plead general damages barred recovery. Held: the appellant's conduct was not conversion because it honestly believed it had a claim of right, but it was liable in trespass for the destruction of the lorry, proved to have occurred while in its custody after it ignored police notice of the true owner. Trespass to a chattel is actionable per se, so pleading general damages was unnecessary. The Shs 20,000,000 award was on the higher side and was reduced to Shs 10,000,000; appeal partly allowed.
Outcome
Appeal partly allowed; general damages reduced from Shs 20,000,000 to Shs 10,000,000
Facts
In May 1975 the appellant company and the respondent each bought a new Tata lorry from the same Kampala dealer. On registration the dealer mistakenly swapped their number plates, so each took delivery bearing the other's number unknowingly. The respondent's lorry was taken by soldiers in 1976, recovered from Sudan and repaired. On re-licensing the plate mix-up was discovered; the respondent surrendered the plate and was issued a new number. In January 1982, while the respondent's lorry was hired to carry salt from the appellant's stores, the appellant seized it claiming ownership. Police investigated and repeatedly informed the appellant (exhibit P9 and later correspondence) that the lorry belonged to the respondent, but the appellant retained it, demanding inspection of the chassis and engine numbers. The vehicle remained in the appellant's yard until June 1985, when it was handed to police and towed away; by then several parts had been removed and it was no longer running. A loss assessor valued replacement at Shs 3,000,000 and found repair uneconomical. The respondent sued for trespass, conversion and destruction of the vehicle.
Issues
- Whether the appellant held the suit vehicle under an honest claim of right such that its conduct did not amount to conversion.
- Whether the appellant was liable in trespass for the cannibalisation and destruction of the vehicle that occurred while it was in the appellant's custody.
- Whether the respondent's failure to plead general damages was fatal to his claim.
- Whether the award of Shs 20,000,000 in general damages was excessive.
Orders
- Appeal allowed in part.
- Award of Shs 20,000,000 general damages set aside.
- Shs 10,000,000 general damages substituted in favour of the respondent.
- Appellant to have half the costs of the suit and of the appeal.
Rules and key headnotes
Cases cited (1)
- Clayton v Le Roy [1911] 2 KB 1031
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.