Wakilii

RevEzra Bikangiso v New Makerere Kobil Station (HCT-00-CC-MA 10 of 2010)

High Court · [2010] UGCOMMC 1 · 2010 Application Dismissed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application to release property attached pending judgment in civil suit
Decision
Application for release of attached property dismissed

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

Held that an applicant seeking release of attached property must establish actual or constructive possession at the date of attachment. Where a memorandum of understanding purporting to transfer a leased vehicle was executed after the head suit was filed, contained deliberate falsehoods about encumbrances, and no independent evidence of possession was shown, the court will find it was entered into to defeat execution and dismiss the application.

Outcome

Application for release of attached property dismissed

Facts

The applicant sought release of a bus (UAK 948T) attached pending judgment in Civil Suit No. 425 of 2009 against M/S Alliaz Tours and Travel Ltd. The applicant claimed to have purchased the bus from Alliaz Pharmacy Ltd pursuant to a Memorandum of Understanding dated 12 December 2009. The respondent had filed the head suit on 12 November 2009 for unpaid fuel supplied to buses including the attached vehicle. The bus was on lease with Stanbic Bank which held the logbook as security. The Memorandum of Understanding warranted the bus was without encumbrance. The same director Mr. Chris Kakama accepted court process in the head suit in November 2009 and signed the Memorandum on behalf of Alliaz Pharmacy Ltd in December 2009. No independent evidence of actual or constructive possession by the applicant was adduced.

Issues

  1. Whether the attached motor vehicle should be released from attachment pending judgment where the applicant claims ownership through a memorandum of understanding executed after the head suit was filed.
  2. Whether the applicant established actual or constructive possession of the attached bus at the time of attachment.
  3. Whether the memorandum of understanding was entered into for the express purpose of defeating execution.

Orders

  • Application dismissed.
  • Costs awarded to the respondent.

Rules and key headnotes

Attachment Before Judgment — Objection Proceedings — Tests for Release of Attached Property
An objector seeking release of property attached before judgment must establish that at the date of attachment he had actual or constructive possession of the property and that he is its owner.
Attachment — Fraudulent Transfers to Defeat Execution
Where a sale agreement is executed after a suit is filed and for the express purpose of saving moveable property from execution, and there is no independent evidence of actual or constructive possession by the alleged purchaser, the objection to attachment will be dismissed.
Sale of Property — Lessee's Power of Sale
A lessee, without special authority to the contrary, cannot sell what is owned by a lessor.

Legislation cited (5)

Cases cited (4)

  • Joseph Mulenga v FIBA (U) Ltd (Miscellaneous Application No. 308 of 1996)
  • Trans Africa Assurance Co v National Social Security Fund (Civil Appeal No. 1 of 1999)
  • Chotabhai M. Patel V Chaturbhai M. Patel & Anor [1958] 1 EA 743 (HCU)
  • Harilal & Co. V Buganda Industries Ltd [1960] 1 EA 318 (HCU)

Full judgment

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The original judgment as reported. Read the original PDF before relying on any passage.

RevEzra Bikangiso v New Makerere Kobil Station (HCT-00-CC-MA 10 of 2010) [2010] UGCommC 1 (16 February 2010)
Source: this page presents Wakilii’s issue analysis and metadata for a publicly reported Ugandan judgment. Any AI-generated summary is marked as such. Judgment text is sourced from the Uganda Legal Information Institute (ulii.org). Wakilii is not affiliated with ULII.