Wakilii

Ssekamwa Sarah and Kigongo George v The Registrar of Titles [2025] UGHC 493

High Court · 2025 Application Granted AI-generated summary ↓ Download Pin to watchlist Add to matter
Jurisdiction
Uganda
Case Type
Application under Section 118 of the Registration of Titles Act for registration of administrators on land title
Decision
Registrar of Titles directed to register applicants as executors on land title

Observed later treatment

No later-treatment classification is recorded for this judgment.

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Holding

Held that administrators who have obtained Letters of Probate and fulfilled all procedural requirements are entitled to be registered on the land title under section 118 of the Registration of Titles Act. The Registrar of Titles had no justifiable reason to halt the registration process after verifying the grant and issuing orders for a substitute page and mutation form. The court directed the Registrar to register the applicants as executors on the title for Bulemezi Block 699 plot 1.

Outcome

Registrar of Titles directed to register applicants as executors on land title

Facts

The applicants were granted Letters of Probate on 4 February 2020 as administrators of the estate of late Wycliffe Andrew Sekamwa Mudeka. On 15 February 2024, they applied to the Registrar of Titles for a special certificate of title for land comprised in Bulemezi Block 699 plot 1, as they could not trace the duplicate certificate. The Registrar verified the grant with Masaka High Court, which confirmed its authenticity on 23 June 2024. The applicants made a police report of loss of title on 19 February 2024. Following the Registrar's direction, they applied for a substitute page, which was ordered on 9 September 2024, and a mutation form was passed on 27 November 2024. On 30 November 2024, the applicants applied to be registered as administrators and proprietors, but the Registrar did not effect the registration despite the applicants fulfilling all requirements.

Issues

  1. Whether the applicants as duly appointed administrators/executors of the estate of late Wycliffe Andrew Sekamwa Mudeka are entitled to be registered on the certificate of title of land comprised in Bulemezi Block 699 plot 1 Land at Naluyambuzi as proprietors under section 118 of the Registration of Titles Act.

Orders

  • Application allowed.
  • The Commissioner Land Registration/Registrar of Titles is directed to register the applicants on the title for land comprised in Bulemezi Block 699 plot 1 land at Naluyambuzi measuring approximately 1,260.40 Acres as Executors of the estate of the late Wycliffe Andrew Sekamwa Mudeka.
  • No order as to costs.

Rules and key headnotes

Registration of Administrators on Land Title — Section 118 Registration of Titles Act
Upon receipt of an office copy of letters of administration and upon application by the administrator, the Registrar shall register the administrator as proprietor and enter a memorandum in the Register Book notifying the appointment, whereupon the administrator becomes the transferee and is deemed to be the proprietor of the land for purposes of dealing with it.
Necessity of Registration for Estate Administration
Administrators must be registered on land titles in order to effectively deal with the property of the deceased and collect debts that were due to the deceased at the time of death.
Registrar of Titles — Duty to Register Upon Compliance with Requirements
Where an administrator has fulfilled all legal and procedural requirements for registration, including verification of the grant by the issuing court and completion of substitute page and mutation procedures, the Registrar of Titles has no lawful justification to halt or delay the registration process.

Legislation cited (4)

Cases cited (1)

  • Re: Estate of Akiki Nyabongo (1773) HCB 52

Full judgment

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Ssekamwa Sarah and Kigongo George v The Registrar of Titles 2025 UGHC 493 (9 July 2025)
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.