Nkugwa v Centenary Rural Development Bank Limited (CIVIL SUIT NO. 165 OF 2016)
Observed later treatment
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Holding
Where a borrower defaulted on a commercial loan secured by three mortgaged properties and paid only 45% of the principal, the court held that the lender was entitled to sell all mortgaged properties to recover the outstanding balance, interest, and costs. The borrower's suit to restrain foreclosure was dismissed. The contractual terms permitted unilateral interest rate variation and foreclosure upon default. The borrower cannot dictate that only one property be sold when all three were pledged as security and no evidence proved one property's value would satisfy the debt.
Outcome
Plaintiff's suit dismissed; Defendant entitled to foreclose on all three mortgaged properties if balance not paid within 7 days
Facts
On 8 October 2014, the Plaintiff borrowed UGX 100,000,000 from the Defendant bank, securing the loan with three properties. He paid UGX 45,043,230, leaving a balance of approximately UGX 54,956,770. In October 2015, the Defendant increased the prime lending rate from 21% to 23% pursuant to a contractual clause permitting unilateral variation. The Plaintiff sought loan rescheduling but was unsuccessful. The Defendant initiated foreclosure proceedings through auctioneers to sell all three mortgaged properties. The Plaintiff argued that only one property should be sold as the three properties were collectively worth over UGX 200,000,000. In September 2017, the parties agreed the Plaintiff would pay UGX 60,000,000 as settlement in one lump sum, but the Plaintiff failed to pay and instead requested instalment payments, which the Defendant refused.
Issues
- Whether the Defendant can foreclose or attach all three properties of the Plaintiff for the recovery of the loan balance due.
- What are the remedies available to the parties?
Orders
- Plaintiff's suit dismissed with costs.
- Counter claim succeeds.
- Plaintiff must pay UGX 60,000,000 balance within 7 days from judgment.
- In case of failure to pay, Defendant entitled to sell the Plaintiff's mortgaged property.
- Any balance after deducting the UGX 60,000,000 loan balance and related expenses to be given to the Plaintiff.
- Defendant awarded general damages of UGX 20,000,000.
- Interest on UGX 60,000,000 balance awarded at 15% per annum from 20 September 2017 till payment in full.
- Defendant awarded costs of both the counter claim and Plaintiff's suit.
Rules and key headnotes
Cases citing this judgment (2)
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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