Wakilii

Iman Shafik Bashir v Habte Ghebrehiwot Zerizchi (Miscellaneous Application No. 2372 of 2024)

High Court · [2025] UGCOMMC 240 · 2025 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application objecting to attachment and sale of property in execution proceedings arising from judgment in Civil Suit No. 56 of 2024
Decision
Application dismissed; applicant ordered to vacate property within 30 days to allow sale in execution

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

Held that property subject to a land sale agreement where the purchaser has paid 68% of the purchase price and taken possession creates an equitable interest in the purchaser that is liable for attachment in execution of a judgment debt owed by the purchaser to the vendor. The judgment debtor's equitable interest in property registered in the judgment creditor's name can be attached to satisfy the debt where the deposit was intended for purchase and completion did not materialise.

Outcome

Application dismissed; applicant ordered to vacate property within 30 days to allow sale in execution

Facts

The respondent obtained judgment against the applicant for USD 130,000 arising from a land sale agreement dated 27 June 2022. Under the agreement, the applicant was to purchase property comprised in LRV 218 Folio 8 for USD 410,000. The applicant paid USD 260,000 initially and later USD 20,000, leaving a balance of USD 130,000. The respondent commenced execution proceedings and attached the suit property for sale. The applicant objected to the attachment on the ground that the property was registered in the respondent's name and therefore not liable for attachment. The applicant and his family were in physical possession of the property. The respondent argued that the applicant had an equitable interest in the property having paid 68% of the purchase price and taken possession, making it the only property available for execution.

Issues

  1. Whether the property comprised in LRV Folio 8, a lease from Mailo Block 257 Plot 998 at Munyonyo, Kyadondo is liable for attachment by the respondent/judgment creditor?
  2. Whether the property comprised in LRV Folio 8, a lease from Mailo Block 257 Plot 998 at Munyonyo, Kyadondo should be released from attachment?
  3. Whether court should issue a warrant of eviction against the applicant in accordance with the Constitution (Land Eviction) (Practice) Directions 2021?

Orders

  • Application dismissed.
  • Property comprised in LRV 218 Folio 8, a lease from Mailo Block 257 Plot 998 at Munyonyo, Kyadondo shall not be released from attachment.
  • Applicant shall render to the respondent vacant possession of the suit property within 30 days from the date of this ruling, for purposes of effecting its sale.
  • Costs of the application awarded to the respondent.

Rules and key headnotes

Execution — Attachment and Sale — Property Liable for Attachment — Equitable Interest
Property liable for attachment in execution of a decree includes property belonging to the judgment debtor or property over which the judgment debtor has a disposing power which may be exercised for his or her own benefit, whether held in the judgment debtor's name or by another person in trust for him or her.
Land Sale Agreements — Equitable Interest — Partial Payment and Possession
A purchaser under a land sale agreement who has made partial payment and taken possession acquires an equitable interest in the property, though legal title remains with the vendor until full payment and registration of transfer. Entry into possession is decisive evidence of a contract to part with ownership and operates as notice to anyone dealing with the land.
Execution — Attachment of Equitable Interest — Judgment Creditor's Rights
Where a judgment debtor has deposited funds for the purchase of property and acquired an equitable interest but completion of the purchase has not materialised, the judgment creditor may leverage that equitable interest to satisfy the judgment debt by attachment and sale, particularly where the property is the only asset the judgment debtor is known to own.
Objector Proceedings — Release from Attachment — Grounds
Property will be released from attachment only if the court is satisfied that the property was not held by the judgment debtor for himself or herself, or that the objector holds the property on his or her own account. Where the judgment debtor has an equitable interest in the property and the judgment debt remains unsatisfied, there is no basis for release from attachment.

Legislation cited (13)

Cases cited (12)

  • Kabiito Karamagi v Yanjian Uganda Company Limited (Miscellaneous Application No. 1202 of 2021)
  • Imelda Nassanga v Stanbic Bank (Civil Appeal No. 10 of 2005)
  • Labanito Okwajja vs Giripasio Okello (1985) HCB 85
  • Kampala Bottlers v Daminico (U) Ltd (Civil Appeal No. 22 of 1992)
  • Patel versus Patel (1992-1993) HCB 137
  • Ndigejjerawa vs Kizito & Anor [1953] 7 ULR 31
  • John Katarikawe vs William Katwiremu & Another [1977] HCB 211
  • Katimbo Foustin Ntambara v Vicent Senoga (Miscellaneous Application No. 1147 of 2022)
  • Khakale E. t/a New Elgon Textiles v. Banyamini W (in the matter of Mugunjo) [1976] HCB 31
  • Biira Esther Kabaseke Kule v Uganda (Miscellaneous Application No. 1261 of 2018)
  • Harilal & Co. vs Buganda Industries Ltd [1960] 318
  • Kasozi Ddamba vs M/s Male Construction Service [1981] HCB 26

Full judgment

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

Iman Shafik Bashir v Habte Ghebrehiwot Zerizchi (Miscellaneous Application No. 2372 of 2024) [2025] UGCommC 240 (25 July 2025)
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.