Commercial Registry - 2021

18 judgments

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18 judgments
Citation
Judgment date
November 2021
Court permitted payment of admitted judgment debt in higher monthly instalments, finding the defendant’s proposed plan unfair and granting leave to appeal.
Civil procedure — Payment of judgment debt in instalments — Instalment orders must fairly balance debtor’s affordability and creditor’s right to prompt satisfaction; default clause enforceable Evidence — Affidavit in reply — No leave required to file an affidavit in reply (distinct from further affidavits). Interest and costs awarded; leave to appeal granted
30 November 2021
September 2021
Loan default established; equitable mortgage over disputed subdivision not proven, but guarantor’s house and vehicle enforceable to satisfy debt.
Equitable mortgage – Creation and proof – Consistent property description and surrender of title deed required; Loan default – entitlement to judgment; Foreclosure and enforcement – guarantor’s property and vehicle enforceable; Sale of confiscated movables – application to reduce indebtedness; Procedure – Originating summons under Order 30 Rule 14.
24 September 2021
The applicant failed to show the arbitral award offended public policy; the court refused to set it aside.
Arbitration — setting aside arbitral award — public policy — narrow, high threshold; scope of arbitration; mistakes of law apparent on face; Rule 23 compliance; finality of arbitral awards.
20 September 2021
A written loan agreement binds the parties despite payment in local currency; interest assessment referred to Registrar under statutory framework.
Contract law – written loan facility – parol evidence rule – payment in local currency does not vary clear written terms – interest computation under Banking and Financial Services Act – referral to Registrar – interest thereafter at 1% above LIBOR – costs to successful lender.
14 September 2021
August 2021
Court struck out clause converting security to sale, revised excessive interest, ordered revised judgment debt and mortgage remedies.
Money-lenders Act — excessive interest — statutory requirement to express or compute annual rate — unconscionable terms; equitable mortgage by deposit of title deeds; clog on equity of redemption — conversion clause void; estoppel cannot validate statutory non-compliance; revision of interest and mortgage remedies.
26 August 2021
Court awarded discounted principal less illegal penal interest; no equitable mortgage without co‑owner consent.
Mortgage law — equitable mortgage; joint ownership and consent to deposit of title deeds; penal interest illegal; compromise/discount binding; burden to prove contractual interest rate and annexures.
23 August 2021
May 2021
Court held respondents liable for the applicant's lost cargo, rejecting liability limitation due to defective airway bill and agency.
Carriage by air — Warsaw Convention applicability and domestic Carriage by Air law — Airway-bill requirements (Article 8(c)) — Agency and beneficial ownership in freight transactions — Limitation of liability (Article 22) — Burden under Article 20 and adverse inference where carrier cannot explain loss.
28 May 2021
Court set aside fraudulent assignment, restored title, held transaction to be a loan, fixed K300,000 repayment with specified interest and dismissed counterclaim.
Property law – registered assignment – alleged forgery and handwriting evidence – fraud vitiating registration; Lands and Deeds Registry Act – cancellation/restoration of certificate of title; Contract characterization – loan (mortgage) versus sale; Money Lenders Act – permissible interest and unconscionable charges; remedies – repayment, sale of secured property, costs.
20 May 2021
April 2021
A judgment debtor (including a company in receivership) cannot claim goods seized in execution; notice set aside, sale stayed 90 days.
Execution – Notice of claim to goods – Judgment debtor (including company in receivership) cannot claim goods seized in execution; Receivership – receiver is agent (Corporate Insolvency Act s13) – locus standi; Consent judgment enforceability; Stay of sale pending settlement.
19 April 2021
Plaintiff proved a K1,539,705.65 debt based on long-standing commercial dealings; defendant's fraud counterclaim was unproven.
Commercial law – recovery of debt for goods and services; agency and apparent authority of company officers; counterclaim alleging fraud requires particularised proof; evidentiary weight of course of dealing and invoice documentation; award of interest where unliquidated damages not proved.
14 April 2021
March 2021
Interpleader upheld: seized trailer and vehicle belong to third parties; guarantors not liable before sale of primary security; stay and costs granted.
Civil procedure – Sheriffs interpleader – Order 17 White Book – Claim to goods seized in execution – Burden to prove title – Enforcement sequence: primary security before guarantors – Stay of execution – Costs.
24 March 2021
Claim for rental arrears dismissed because defendant failed to prove arrears remained after distraint; lease not shown to be unregistered.
Lease – existence and commencement – rent obligation date – distraint (warrant of distress) – burden of proof as to outstanding arrears after distraint – effect of non-registration allegation on enforceability of lease.
18 March 2021
Court may hear applications to amend pleadings or witness statements after trial commencement where Order 18 and justice permit.
Civil procedure – interlocutory applications – Order 19 r.3 SI No.58/2020 prohibiting interlocutory applications within 14 days of trial – Order 19 r.3(4) discretion and reasonable diligence – Amendment power of court under Order 18 r.1 – Witness statements and Practice Note 38/2A/9 – timing of objections to witness statements.
15 March 2021
Defendant’s challenge to a writ’s amount dismissed; writ correctly reflected the debt accelerated by default.
Civil procedure – Execution – Writ of fi. fa. – Issuance after default under conditional installment order – Accuracy of amount stated – Order 45(1)(5) White Book (editorial notes) – Cubitt v Gamble distinguished – Application to set aside for irregularity dismissed; costs awarded.
10 March 2021
Whether an agent’s apparent/actual authority binds the principal and whether a bank is negligent in opening the principal’s account.
Agency/Partnership – nature of relationship and profit-sharing; Actual and apparent authority of agent; Turquand/indoor management rule; Bank’s good-faith reliance on agent’s authority; Burden of proof for fraud and negligence; Limited monetary award and dismissal of damages claims.
5 March 2021
Whether a notice of admitted indebtedness permits foreclosure or sale absent clear admission and documentary proof of a legal mortgage.
:[
5 March 2021
February 2021
Plaintiff proved contracts and payment; court ordered refunds with interest, denied specific performance and attachment, and awarded token damages.
Contract law – breach of contract; specific performance discretionary and inappropriate against absent/respondent of unknown whereabouts; refund of payments ordered; attachment of chattel requires clear title; unliquidated damages require evidential proof; interest awarded at 2% above LIBOR; Commercial List procedural compliance and substituted service.
1 February 2021
Contract incorporated tender specifications; ladders unfit for intended purpose—plaintiff's claim dismissed; each party to bear own costs.
Contract formation — incorporation of tender/quotation and technical specifications into Purchase Order by reference; admissibility of extrinsic documents; Sale of Goods Act s.14 — merchantable quality and fitness for a particular purpose; acceptance and rejection of goods; costs discretion.
1 February 2021