R. L Jain Limited v Nganda Kaweesa Fredrick (Civil Suit No. 826 of 2024)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The court held that the defendant was indebted to the plaintiff for unpaid loan amounts, but reduced the contractual interest rate from 6% per month (72% per annum) to 2% per month (24% per annum) on the grounds that the original rate was harsh, excessive, and unconscionable under Section 26(1) of the Civil Procedure Act and Section 88 of the Tier 4 Microfinance Institutions and Money Lenders Act. The defendant's claim that payments totalling UGX 35,000,000 were made towards the suit loans was rejected for lack of cogent evidence linking those payments to the loans in issue.
Outcome
Judgment entered for the Plaintiff with reduced interest rate on outstanding loan amounts
Facts
The plaintiff, a money lender, advanced five loans to the defendant between November 2022 and February 2023 totalling UGX 46,134,000 at an interest rate of 6% per month. The defendant made partial payments of UGX 11,534,000 on two of the loans. The plaintiff claimed an outstanding balance of UGX 72,380,000 including accumulated interest. The defendant admitted receiving the loans but contended he had paid UGX 35,000,000, leaving a balance of only UGX 11,134,000. The defendant also argued that the 6% monthly interest rate was harsh and unconscionable. The court found that the defendant failed to prove the alleged UGX 35,000,000 payment related to the suit loans, as the receipts adduced were dated after service of a notice to show cause in a separate execution matter and the defendant could not link specific payments to specific loans.
Issues
- Whether the Defendant is indebted to the Plaintiff in the liquidated sum of UGX 72,380,000/=.
- What remedies are available to the parties.
Orders
- The Defendant shall pay the Plaintiff the outstanding principal sum and the accrued interest at the rate of 24% per annum, the equivalent of 2% per month, on each disbursed loan from the date of disbursement until the date of filing the suit.
- Interest at the rate of 24% per annum is awarded on the sum in (1) above from the date of filing the suit until payment in full.
- Costs of the suit are awarded to the Plaintiff.
Rules and key headnotes
Legislation cited (11)
- Evidence Act Cap. 8 s.101
- Evidence Act Cap. 8 s.102
- Evidence Act Cap. 8 s.103
- Evidence Act s.91
- Contracts Act Cap. 284 s.9(1)
- Contracts Act Cap. 284 s.32(1)
- Civil Procedure Act Cap. 282 s.26(1)
- Civil Procedure Act Cap. 282 s.26(2)
- Civil Procedure Act Cap. 282 s.27(2)
- Tier 4 Microfinance Institutions and Money Lenders Act Cap. 61 s.88(1)(a)
- Tier 4 Microfinance Institutions and Money Lenders Act Cap. 61 s.88(1)(c)
Cases cited (15)
- John Bwiza v Patrick Yowasi Kadama (Court of Appeal Civil Appeal No. 35 of 2011)
- Sebuliba Busuulwa v Co-operative Bank Ltd [1982] HCB 129
- William Kasozi v DFCU Bank Ltd (High Court Civil Suit No. 1326 of 2000)
- Omega Bank Plc Vs O.B.C. Limited [2005] 8 NWLR (pt.928) 547
- Fina Bank Ltd v Spares and Industries Ltd [2000] 1 EA 52
- Mwijukye Cephus v Kampala Financial Services Limited & Another (High Court Civil Suit No. 35 of 2021)
- R.L Jain v Loy Komugisha and 2 Others (High Court Civil Suit No. 98 of 2018)
- Rajnish Jain (Administrator of the Estate of the late R.L Jain) v Lokii Peter Abraham (Civil Suit No. 277 of 2013)
- Jas Ventures International Limited v Atuhaire Juliet (Civil Suit No. 676 of 2021)
- Juma v Habibu [1975] EA 108
- Milly Masembe v Sugar Corporation (U) Ltd and Another (Supreme Court Civil Appeal No. 1 of 2000)
- Wallersteiner v Moir [1975] 1 All ER 849
- Mohanlal Kakubhai Radia v Warid Telecom Uganda Ltd (High Court Civil Suit No. 224 of 2011)
- Hash Security Company Limited v Roko Construction Limited (High Court Civil Suit No. 39 of 2022)
- Uganda Development Bank v Muganga Construction Co. Ltd [1981] HCB 35
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.