Standard Chartered Bank (U) Ltd. v Grand Hotel (U) Ltd. (CIVIL APPEAL NO. 13 OF 1999)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The Court of Appeal held that a court cannot decide a case on an issue that was neither pleaded nor left to it for decision by the parties, and that the trial judge's reliance on the unpleaded ground that the demand letter was unsigned caused a failure of justice. Since the matter was heard on its merits, dismissal (not striking out) was the proper order below. On the cross-appeal, the Court held a decree is no longer an essential document in a record of appeal unless its date or terms are disputed, and Originating Summons was the correct procedure for foreclosure under Order 34 rule 3A. The appeal was allowed and the cross-appeal dismissed.
Outcome
Appeal allowed, High Court judgment set aside, judgment entered for the appellant Bank; cross-appeal dismissed
Facts
The respondent Company was registered proprietor of two leasehold properties in Kampala. In 1965 it deposited the certificates of title with the appellant Bank as security for two loan facilities payable in pounds sterling, executing a memorandum of deposit requiring repayment on demand. In 1972 the shareholders left Uganda during the "Economic war" and the properties were expropriated and transferred to the Departed Asians Properties Custodian Board under the Assets of Departed Asians Decree 1973. In 1991 the respondent repossessed the properties under the Expropriated Properties Act 1982 and demanded release of the titles, claiming the mortgage had been extinguished under section 19 of the Limitation Act. The Bank contended the debt had been acknowledged during government custody and demanded payment of £158,376.89. When the respondent failed to pay, the Bank took out an Originating Summons for foreclosure and sale. The trial judge resolved all framed issues in the Bank's favour but declined foreclosure solely because the demand letter (Annexture D) was unsigned, an issue never pleaded.
Issues
- Whether the trial judge erred in dismissing the claim on the ground that the letter of demand (Annexture D) was not signed, an issue that had not been pleaded or raised by the parties.
- Whether, having found the appellant had an accrued enforceable right, the suit should have been struck out rather than dismissed.
- Whether the appeal was incompetent for want of a formal drawn-up order or decree.
- Whether the Originating Summons was the correct procedure for the relief sought.
Orders
- Appeal allowed.
- Judgment of the High Court set aside and judgment entered for the appellant Bank.
- Cross-appeal dismissed.
- Costs of the appeal and in the court below awarded to the appellant Bank, plus the costs of the cross-appeal.
Rules and key headnotes
Legislation cited (8)
- Mortgage Decree 1974 s.2
- Civil Procedure Rules Order 34 rr.3A and 7
- Limitation Act Cap. 70 s.19
- Assets of Departed Asians Decree 1973 (Decree No. 27 of 1973)
- Expropriated Properties Act 1982
- Rules of the Court of Appeal r.81
- Rules of the Court of Appeal r.101(b)
- Rules of the Court of Appeal r.86
Cases cited (5)
- Captain Harry Gandy v Caspar Air Charter Ltd (1956) 23 EACA 139
- Blay v Pollard and Morris (1930) 1 KB 682
- Fernandes v People Newspapers Ltd
- Odd Jobs v Mubia (1970) EA 476
- Kulsumbai v Abdulhussein (1957) EA 699
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.