Yako Bank Uganda Limited v Gidudu [2025] UGCOMMC 35
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The High Court held that the Chief Magistrate's Court lacked pecuniary jurisdiction to entertain a suit seeking cancellation of a mortgage agreement valued at over UGX 50,000,000, notwithstanding the plaintiff's claim that his equitable interest was valued below that threshold. The prayers sought — cancellation of contracts exceeding the magistrate's jurisdictional limit — could not be granted by that court. The temporary injunction issued by the Chief Magistrate was set aside as a nullity for want of jurisdiction.
Outcome
Temporary injunction set aside for lack of jurisdiction; matter to be transferred to the High Court
Facts
Tusingwire Eliab Elikanah obtained a loan of UGX 60,000,000 from Yako Bank Uganda Limited, secured by a mortgage over land comprised in Block 121 Plot 932 at Nangambo. Tusingwire defaulted, owing UGX 56,526,665. When the bank commenced foreclosure proceedings, Gidudu Badru W. (the respondent) filed Civil Suit No. 21 of 2023 at Kasangati Chief Magistrate's Court, claiming he held an equitable interest in the mortgaged land valued at UGX 40,200,000, and seeking cancellation of the mortgage. He also filed Miscellaneous Application No. 09 of 2023 for a temporary injunction to stop the sale. The bank raised a preliminary objection that the Chief Magistrate's Court lacked pecuniary jurisdiction, as the matter involved cancellation of a mortgage exceeding UGX 50,000,000. The Chief Magistrate overruled the objection and granted the temporary injunction, holding that the plaintiff's equitable interest was valued below UGX 50,000,000 and thus within its jurisdiction. The bank then filed this civil revision application in the High Court seeking to set aside the injunction on jurisdictional grounds.
Issues
- Whether the Chief Magistrate's Court exercised jurisdiction not vested in it in law when it heard and determined a temporary injunction application in a matter involving cancellation of a mortgage agreement valued above UGX 50,000,000.
- Whether the Chief Magistrate's Court acted illegally and with material irregularity by granting a temporary injunction without ordering the respondent to pay 30% of the forced sale value of the mortgaged property or the value of the loan as required by Regulation 13 of the Mortgage Act Regulations.
Orders
- The orders of temporary injunction issued by Her Worship Kainza Beatrice on 6th September 2023 at Kasangati Chief Magistrate's Court are set aside for lack of jurisdiction.
- The Applicant is awarded the costs of this application.
Rules and key headnotes
Legislation cited (7)
- Civil Procedure Act s.83
- Civil Procedure Act s.98
- Civil Procedure Act s.4
- Civil Procedure Rules Order 5 Rules 1, 2 and 3
- Magistrate's Court Amendment Act 2007 s.207(1)(a)
- Magistrate's Court Amendment Act 2007 s.207(5)
- Mortgage Act Regulations Regulation 13
Cases cited (5)
- Baku Raphael Obudra and Another v Attorney General (Supreme Court Criminal Appeal No. 1 of 2005)
- Ajuna Jackson Francis and 2 others v Lake View Enterprises & Another (High Court Miscellaneous Cause No. 02 of 2019)
- Kibalama Mugwanya v Butebi Investment Enterprises Ltd (Court of Appeal Civil Appeal No. 190 of 2013)
- Shumuk Properties Ltd v Guaranty Trust Bank (U) Ltd (High Court Miscellaneous Application No. 231 of 2018)
- [1989] KLR 1
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.