Wakilii

In the Matter of an Application for Leave of Court to file an Inventory and Account out of time By Kasula William Majanja (Miscellaneous Application No. 2286 of 2025)

High Court · [2025] UGHCFD 162 Application Granted AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for leave to file inventory and account out of time arising from Administration Cause No. 0552 of 2024
Decision
Administrator granted leave to file inventory and accountability within 30 days

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

An administrator granted letters of administration in October 2024 applied for leave to file an inventory out of time. The court held that the delay was justified by pending land title processing and negotiations with squatters on estate property. The court granted leave, emphasising that the primary purpose of an inventory is to establish what the estate consists of, not to show completed distribution. The administrator was given 30 days to file the inventory showing property details, credits, debts, beneficiaries, and proposed distribution.

Outcome

Administrator granted leave to file inventory and accountability within 30 days

Facts

Letters of Administration for the estate of the late Bafirawala Aligizanda were granted to Kasula William Majanja on 31 October 2024. The administrator was required to file an inventory within six months from the grant but did not do so. The administrator applied for leave to file out of time, citing pending land title processing and ongoing negotiations between beneficiaries and squatters on estate property. The administrator attached a draft inventory showing willingness to fulfill obligations. Only approximately three months had passed since the statutory deadline expired.

Issues

  1. Whether there is sufficient cause to warrant leave of court to file the inventory out of time.

Orders

  • Application successful.
  • Administrator granted leave to file inventory out of time showing: Part A (deceased's details, administration details); Part B (properties with documentary evidence and status); Part C (credits); Part D (debts); Part E (beneficiaries and IDs); Part F (proposed distribution with family minutes); Part G (property already distributed with proof).
  • Inventory and accountability to be filed within thirty (30) days from date of ruling.
  • No order as to costs.

Rules and key headnotes

Administration of Estates — Inventory — Purpose and Content
The primary purpose of the statutory requirement to file an inventory is for the administrator to establish what the estate consists of and to inform the court and beneficiaries of the property, its status, and any adverse claims, not to show that distribution has been completed.
Extension of Time — Test for Sufficient Cause
In determining an application for extension of time, the court must consider: (1) whether the applicant has established sufficient reasons for the extension; (2) whether the applicant is guilty of dilatory conduct; and (3) whether any injustice will be caused if the application is not granted.
Extension of Time — Meaning of Sufficient Cause
The words 'sufficient cause' should receive a liberal construction in order to advance substantial justice, where no negligence, inaction, or want of bona fides is imputed to the applicant.
Administration of Estates — Inventory — Extension of Time
Where an administrator demonstrates that delay in filing an inventory was caused by circumstances beyond their control and not by negligence, and where only a short period has passed since the statutory deadline and the administrator shows willingness to comply, the court may exercise its discretion to grant an extension to prevent injustice to beneficiaries.

Legislation cited (5)

Cases cited (6)

  • Hajjat Ndagire and Another v Muhammad Kasozi and Others (High Court Civil Suit No. 40 of 2014)
  • Molly Kyallikunda Turinawe and Others v Engineer Turinawe and Another (Supreme Court Civil Appeal No. 27 of 2010)
  • Mugo and ors vs Wanjiru & another [1970] EA 481
  • The Registered Trustees of the Archdiocese of Dar es Salam V the Chairman Bunju Village Government & Ors
  • Gideon Mosa Onchwati V Kenya Oil Co. Ltd & Anor [2017] KLR
  • Huo Yan Fang v Dong Hoon Kim (High Court Civil Suit No. 22 of 2018)

Full judgment

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

In the Matter of an Application for Leave of Court to file an Inventory and Account out of time By Kasula William Majanja (Miscellaneous Application No. 2286 of 2025) [2025] UGHCFD 162 (11 September 2
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.