Nayebale Mideas v Tropical Bank and Another (Miscellaneous Application No.25 of 2024)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that when a court grants leave to amend pleadings based on proposed amendments, the party may not file materially different amendments introducing new parties or new causes of action without seeking fresh leave. The counter-claim filed by the first respondent introduced a new counter-defendant and a new cause of action not contemplated in the proposed amendment upon which leave was granted. This constituted an abuse of court process. The counter-claim was struck out under the court's inherent jurisdiction.
Outcome
Counter-claim struck out; amended written statement of defence remains on record
Facts
The applicant filed suit against Tropical Bank and Bamwesigye Benon. In Miscellaneous Application No. 51 of 2023, Tropical Bank sought and obtained leave to amend its written statement of defence to correct the outstanding loan amount from UGX 15,000,000 to UGX 24,000,000 and to introduce a counter-claim against the second respondent only for recovery of the loan. The proposed amended pleadings were annexed to that application. However, the amended written statement of defence and counter-claim filed on 09/02/2024 materially differed from the proposed pleadings. The filed counter-claim targeted the applicant instead of the second respondent and changed the cause of action from recovery of a loan to a claim for general damages for interference with mortgaged property. The applicant applied to strike out the amended pleadings on the ground that they exceeded the scope of the leave granted.
Issues
- Whether the amended pleadings fall within the leave granted by the Court in Miscellaneous Application No. 51 of 2023.
- Whether the amended pleadings should be struck out.
- What remedies are available to the parties.
Orders
- The counter-claim filed by the 1st respondent within the Amended Written Statement of Defence and Counter-claim dated 09/02/2024 is struck out for being filed in contravention of the leave granted in Miscellaneous Application No. 51 of 2023 and for constituting an abuse of court process.
- The amended written statement of defence is proper before Court.
- The costs of this application will be in the cause.
Rules and key headnotes
Legislation cited (6)
Cases cited (7)
- Scovia Mutereza v Margret Kakacumbira and Another (High Court Civil Suit No. HCT-05-LD-CS-0274 of 2022)
- Makula International Ltd v His Eminence Cardinal Emmanuel Nsubuga [1982] HCB 11
- Gaso Transport Services (Bus) Ltd v Obene [1990-94] EA 88
- Huawei Technologies (U) Co. Ltd v Evepeak Consults & Technical Services Ltd (Miscellaneous Application No. 189 of 2011)
- Amit Jain v Hon. Lokii Peter Abrahams (High Court Miscellaneous Application No. 0695 of 2014)
- Steward v North Metropolitan Tramways Co (1886) 16 QBD 178
- G. L. Baker Ltd v Medway Building & Supplies Ltd [1958] 1 WLR 1216
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.