Ogugua & Anor v Mania (CIVIL SUIT No. 0013 OF 2012)
Observed later treatment
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Holding
Held that where a contract for sale of land is executed on different dates by vendor and purchaser, the contract becomes binding on the date of exchange—when the last party signs. The three-month payment period runs from that date. The vendor breached the contract by refusing to complete the transaction after the purchasers tendered the balance within the stipulated time. The vendor's offer of an alternative plot constituted repudiation. The purchasers are entitled to recovery of the part payment, special damages for legal fees, general damages reflecting the 30% surcharge agreed in the contract, and costs.
Outcome
Judgment entered for the plaintiffs for shs. 60,000,000/= (previously decreed), shs. 700,000/= special damages, shs. 18,000,000/= general damages, and costs.
Facts
On 27 March 2012, the plaintiffs (husband and wife, UK residents) and the defendant entered into a contract for the sale of plot 25 Awudele Crescent, Arua, at shs. 120,000,000/=. The plaintiffs paid shs. 60,000,000/= immediately. The balance of shs. 60,000,000/= was to be paid within three months. The vendor signed on 27 March 2012; the purchasers signed on or about 18 April 2012. The plaintiffs transacted through agents in Uganda (Irene Opio, Lilian Ayikoru Adriko, and broker Kafu Nasur). In June–July 2012, the plaintiffs' agents attempted to deliver the balance but the defendant became evasive. The agents also demanded a shs. 20,000,000/= commission, which the defendant refused. In August 2012, the defendant rejected the balance and offered an alternative plot (plot 16 Jerekede Road), stating that her school's Board of Governors had stopped her from selling plot 25. The plaintiffs rejected the alternative plot and demanded refund of their part payment, which the defendant refused. A judgment on admission for shs. 60,000,000/= (with 6% interest) was entered on 31 October 2012.
Issues
- Whether the defendant breached the contract of sale of plot No. 25 Awudele Crescent in Arua Municipality.
- What are the remedies available to either party?
Orders
- Judgment entered for the plaintiffs for recovery of shs. 60,000,000/= previously decreed on 31st October 2012.
- Judgment entered for special damages of shs. 700,000/=.
- Judgment entered for general damages of shs. 18,000,000/=.
- Costs of the suit awarded to the plaintiffs.
Rules and key headnotes
Cases cited (4)
- Williston on Contracts § 6:1 (4th ed. 2009-2010)
- Eccles v Bryant and Pollock [1948] Ch 93
- Domb v Isoz [1980] 2 WLR 565
- Johnson v Agnew [1979] 2 WLR 487
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
The original judgment as reported. Read the original PDF before relying on any passage.