Megallies Distillers ( U) Ltd & Anor v Byensi & Anor (HCT-00-CC-MC 9 of 2009)
Observed later treatment
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Holding
The court held that an ex parte application for distress for rent under section 2 of the Distress for Rent (Bailiffs) Act was not illegal in the absence of express procedural legislation, and a landlord may distress for rent as long as the tenant's property remains on the premises even after termination of the tenancy. Items seized that were not listed in the distress order must be returned to the applicants. Questions of set-off for improvements and validity of a second lease agreement are contentious matters requiring resolution in a regular suit. Order 22 of the Civil Procedure Rules does not apply to distress for rent proceedings.
Outcome
Items not covered by the distress order ordered to be returned to the applicants within 14 days; items lawfully distressed to remain in custody pending resolution of the main suit (HCCS 75 of 2007); multiplicity of miscellaneous applications arising from the same dispute ordered closed
Facts
The applicants entered into a tenancy agreement with the respondents in June 2006 for premises to establish a distillery. The applicants paid six months' rent and made renovations worth approximately UGX 57,000,000. A dispute arose when the respondents required the applicants to sign a second lease agreement in September 2006, which the applicants refused to honour, claiming it was unconscionable. In August 2007, the second applicant was ordered by police not to return to the premises following theft charges (which proved false). On 3 August 2007, an inventory of property on the premises was signed by both parties. On 4 October 2007, the respondents obtained an ex parte order for distress for rent from the Chief Magistrates Court Masindi, alleging the applicants had abandoned equipment on the premises. The applicants brought this application seeking release of the property, arguing there was no subsisting landlord-tenant relationship at the time of distress, that they were entitled to set off rent against improvements, and that the distress order did not cover all items seized.
Issues
- Whether the order for distress for rent was illegal for being made ex parte without notice to the applicants.
- Whether a landlord-tenant relationship existed at the time the order for distress was made.
- Whether the applicants were entitled to set off rent against improvements made to the premises.
- Whether items not listed in the distress order but retained by the respondents should be returned.
- Whether the procedure under Order 22 of the Civil Procedure Rules applied to execution of a distress order.
Orders
- Items listed in the inventory but not covered by the distress order to be returned to the applicants or made good within 14 days.
- Chief Registrar to cause a fresh inventory of the items legally distressed and assess the condition of their storage.
- If storage not satisfactory, appropriate storage to be arranged at the respondents' costs.
- Chief Registrar to cause the immediate and speedy trial of HCCS No. 75 of 2007 so that legal rights of the parties are determined.
- All miscellaneous applications arising out of MA 044 of 2007 to be closed, including MA 064/2007, MA 065/2007, MA 002/2008, MA 102/2008, MA 078/2008, MA 011/2009, MA 012/2009, MA 097/2009.
- Each party to bear their own costs.
Rules and key headnotes
Legislation cited (6)
- Civil Procedure Act s.92
- Civil Procedure Act s.98
- Civil Procedure Rules O.52
- Distress for Rent (Bailiffs) Act s.2
- Civil Procedure Rules O.22
- Judicature Act s.33
Cases cited (5)
- Wampewo Service Station v Italian Garage (Pizzandi) Ltd [1963] EA 455
- Tumushabe v Anglo African Ltd (Supreme Court Civil Appeal No. 7 of 1999)
- Tumushabe v M S Anglo African and Another (Supreme Court Civil Appeal No. 79 of 1999)
- Lyons v Elliott (1876) 1 QBD 210
- Assist (U) Ltd v Italian Asphalt and Haulage Ltd and Another (High Court Civil Suit No. 1291 of 1999)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.