In Re Application by Michael Ndichu Mburu (Receiver Manager of Mandeeq Africa Ltd) (In Receivership) (Miscellaneous Cause No. 9 of 2008)
Observed later treatment
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Holding
Held that the application satisfied all statutory requirements under the Foreign Judgments (Reciprocal Enforcement) Act and Rules. The Kenyan judgment was brought within the six-year limitation period, remained unsatisfied, and was enforceable in the original court. Kenya, as a Commonwealth territory, falls within the Act's scope per SI No. 35/2002. The application was properly titled, supported by appropriate affidavits containing required information, and accompanied by a certified copy of the judgment. Leave granted to register the judgment, with execution stayed for 14 days to allow the debtor to apply to set aside registration.
Outcome
Foreign judgment registered; applicant authorised to take possession of trucks for preservation pending any application to set aside registration within 14 days
Facts
Mandeeq Africa Limited, a Kenyan transport company, created a debenture on 5 September 2007 in favour of Fina Bank Limited to secure a loan facility of Kshs 89,600,000. The company defaulted, and on 17 July 2008 the bank appointed Michael Ndichu Mburu as Receiver/Manager. On 23 July 2008, the Kenyan High Court granted an order allowing the receiver to attach, seize and take possession of all charged assets for preservation and accounting. The total debt including accrued interest amounted to Kshs 113,836,987 (equivalent to UG shs 2,732,087,688). After the Kenyan order was issued, most of the charged assets were allegedly fraudulently transferred into Uganda by the company's directors without the receiver's knowledge. The receiver applied to register the Kenyan judgment in Uganda to enable attachment of the assets within Ugandan jurisdiction.
Issues
- Whether the application complies with the conditions set out in the Foreign Judgments (Reciprocal Enforcement) Act Cap 9 and the Foreign Judgments (Reciprocal Enforcement) Rules for registration of the Kenyan judgment.
Orders
- Leave to register the judgment of the High Court of Kenya obtained on 23rd July 2008 in Miscellaneous Application No. 556 of 2008 is hereby granted as prayed.
- The Applicant shall upon registration of the judgment take possession of the trucks listed in the judgment for purposes of preservation only, pending any application to set aside the registration.
- Any application for setting aside registration of the judgment shall be made within 14 days after service of this order on the Debtor.
- Execution of the judgment shall not issue until after the expiry of the period.
- Costs of the applicant shall be provided for by the applicant.
Rules and key headnotes
Legislation cited (5)
- Foreign Judgments (Reciprocal Enforcement) Act Cap 9 s.3
- Foreign Judgments (Reciprocal Enforcement) Act Cap 9 s.5
- Foreign Judgments (Reciprocal Enforcement) Rules r.4
- Evidence Act s.56(i)
- Foreign Judgments (Reciprocal Enforcement) (General Application) Order SI No. 35/2002 s.2
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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