Wakilii

Singh v Bhasker and Company (Civil Appeal No. 11 of 1956)

East African Court of Appeal · [1956] EACA 7 · 1956 Appeal Allowed AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Civil appeal from Resident Magistrate's Court judgment on procedural capacity to sue
Decision
Respondent's suit dismissed for lack of capacity to sue in business name

Observed later treatment

No later-treatment classification is recorded for this judgment.

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AI-generated summary. This summary was generated by AI from the full text of the judgment. It may contain errors or omissions—always read the source judgment before relying on it.

Holding

A single person carrying on business under a name other than his own has no right to sue in the business name. The suit must be instituted in the individual's own name, trading as the business. Order 29 rules 1 and 9 of the Civil Procedure rules do not permit an individual to sue in a business name.

Outcome

Respondent's suit dismissed for lack of capacity to sue in business name

Facts

The respondent instituted suit in the Resident Magistrate's Court in the name "Bhasker and Company". The Resident Magistrate ruled that Order 29 rules 1 and 9 of the Civil Procedure rules permitted an individual to sue in a business name. The appellant challenged this ruling on appeal, arguing that a sole proprietor cannot sue in a business name but must sue in his own name trading as the business.

Issues

  1. Whether a sole proprietor carrying on business under a business name has the right to institute proceedings in that business name rather than in his own name.

Orders

  • Appeal allowed.
  • Judgment of the Resident Magistrate's Court set aside.
  • Respondent's suit dismissed.
  • Costs awarded to appellant here and below.

Rules and key headnotes

Civil Procedure — Capacity to Sue — Business Names — Sole Proprietor
It is not open to a single person carrying on business under some name other than his own to sue in the name under which he carries on business.

Legislation cited (2)

  • Civil Procedure Order 29 rule 1
  • Civil Procedure Order 29 rule 9

Cases cited (2)

  • George and Company v Pritam's Auto Service (Civil Case No. 1804 of 1953)
  • Velji Arjan Patel v National Contractors (1954) 21 EACA 39

Full judgment

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

Singh v Bhasker and Company (Civil Appeal No. 11 of 1956) [1956] EACA 7 (1 January 1956)
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.