Wakilii

Masenge v A.G of Republic of Burundi (Application 5 of 2013)

East African Court of Justice · [2014] EACJ 12 · 2014 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application for interlocutory injunction arising from Reference No. 9 of 2012 concerning alleged unlawful occupation of land property
Decision
Application dismissed; main Reference to proceed to hearing

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

The Court declined to grant an interlocutory injunction restraining the Government of Burundi from using disputed land. While the Applicant's registered land title raised serious triable issues warranting interrogation under the Treaty, the Applicant failed to demonstrate that he would suffer irreparable injury that could not be compensated by damages. The balance of convenience did not favour granting the injunction. The application was dismissed with costs to abide the outcome of the main Reference.

Outcome

Application dismissed; main Reference to proceed to hearing

Facts

The Applicant, a Burundian resident, held a registered land title to 24 hectares in Gihanga Commune, Bubanza Province, issued by the Registrar of Land Titles on 9 August 2009. He alleged that local officials and their supporters encroached on his land and that the Government of Burundi, through the Governor of Bubanza Province, was parcelling out and selling the property, erecting buildings including a mosque, primary school, and football stadium, and permitting fish farming activities. Despite his complaints to the Minister of Home Affairs and other authorities, no action was taken to protect his property rights. The Applicant filed a Reference before the EACJ alleging violations of Treaty provisions and sought an interlocutory injunction to stop all construction and use of the land pending determination of the main Reference. The Respondent denied the Applicant's title was lawfully acquired and argued that a similar case was pending in the Administrative Court of Bujumbura.

Issues

  1. Whether the Court should grant an interlocutory injunction restraining the Respondent from using or changing the disputed land property.
  2. Whether the Applicant has demonstrated a serious question to be tried regarding his claim to the disputed land.
  3. Whether the Applicant would suffer irreparable injury if the injunction is not granted.
  4. Whether the balance of convenience favours granting the interlocutory injunction.

Orders

  • Application for interlocutory injunction dismissed.
  • Costs to abide the outcome of Reference No. 9 of 2012.

Rules and key headnotes

Interlocutory Injunctions — Test for Grant — Serious Question to be Tried
On an application for an interlocutory injunction, the court must be satisfied that there is a serious question to be tried. The material available to the court at the hearing must disclose that the claimant has real prospects of succeeding in the claim for a permanent injunction at trial. The former requirement that the claimant establish a strong prima facie case has been removed.
Interlocutory Injunctions — Irreparable Injury — Quantifiable Loss
An interlocutory injunction will not be granted unless the applicant demonstrates that without the injunction, irreparable injury would be suffered that cannot be compensated by an award of damages. Where any potential injury is quantifiable and damages would be appropriate compensation, the injunction should be refused.
Interlocutory Injunctions — Balance of Convenience
Even where an applicant's claim raises serious triable issues, the court must consider whether the balance of convenience favours granting the injunction. The grant of an interlocutory injunction is an exercise of the court's discretion which must be exercised judiciously at all times.
Land Title — Prima Facie Evidence of Interest
A registration certificate of land property issued by the Registrar of Land Titles may serve as prima facie indication that the holder has an interest in the property, particularly where no action has been taken to revoke the title and no legal proceedings have been undertaken to show that the title was unlawfully acquired or that the land was unlawfully occupied.

Legislation cited (16)

  • Treaty for the Establishment of the East African Community Article 3(3)(b)
  • Treaty for the Establishment of the East African Community Article 6(d)
  • Treaty for the Establishment of the East African Community Article 7(2)
  • Treaty for the Establishment of the East African Community Article 8(4)
  • Treaty for the Establishment of the East African Community Article 27(1)
  • Treaty for the Establishment of the East African Community Article 27(2)
  • Treaty for the Establishment of the East African Community Article 30(1)
  • Treaty for the Establishment of the East African Community Article 30(2)
  • Treaty for the Establishment of the East African Community Article 23(1)
  • EACJ Rules of Procedure Rule 1(2)
  • EACJ Rules of Procedure Rule 2(2)
  • EACJ Rules of Procedure Rule 2(3)
  • EACJ Rules of Procedure Rule 2(4)
  • EACJ Rules of Procedure Rule 21(2)
  • Burundi Land Act 2011
  • Constitution of Burundi

Cases cited (4)

  • Giella v Cassman Brown & Co Ltd (1973) EA 358
  • American Cyanamid Co v Ethicon Ltd [1975] All ER 504
  • Mbidde Foundation Ltd and Margaret Zziwa v Secretary General of the East African Community and Attorney General of Uganda (EACJ Application No. 5 of 2014)
  • Kahoho v Secretary General (EACJ Application No. 5 of 2012)

Full judgment

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

Masenge v A.G of Republic of Burundi (Application 5 of 2013) [2014] EACJ 12 (18 June 2014)
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.