THE REPUBLIC OF UGANDA

THE HIGH COURT OF UGANDA AT KAMPALA

LAND DIVISION

1.ANJELINA MUTONI

2.KATONGOLE CELESTINO ::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::APPLICANTS

Versus

PATEL KUMAR::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::::RESPONDENT

RESPONDENTS AFFIDAVIT IN REPLY

I PATEL KUMAR of C/o M/S Firm C3 & Co. Advocates, hereby swear and state as follows.

1. That I am a male adult Ugandan of sound mind, a respondent in Miscellaneous Cause No. 001 of
2023 and I depone this affidavit in that capacity.
2. That I have read together with the help of my Lawyers of M/s Firm C3 & Co. Advocates the
applicants’ affidavit in support and understood the same.
3. That I have been advised by my lawyers’ which advice I verily believe to be true that the
applicants’ affidavit lacks merit and the applicant shall put to strict proof thereof.
4. That on the 4th day of November, 2022 I purchased land Kyadondo Block 83plot 21 at Bubale in
Wakiso District from the 1st Applicant’s late husband George Mutoni at Ugshs 1,000,000,000/=.
5. That I made a part payment of Ugshs 550,000,000/= which the 1 st Applicant’s husband
acknowledged receipt thereof. See a copy of the sales agreement hereto annexed marked “A.”
6. That after I took possession on the said suit land, I started my development to wit a poultry
farm, banana plantation and a piggery.
7. That I was further advised by my said lawyers which advise I verily believe to be true that after
making the said payments I obtained equitable interest with legal claim in the said land.
8. That to my surprise the 1st Applicant’s late husband identified a buyer who was paying him much
more money than we agreed in the sales agreement and he hurriedly sold the said suit land to
the 2nd Applicant without my consent.
9. That the 1st Applicant has vowed to only refund Ugshs 470, 000,000/= million out of the Ugshs
550,000,000/= that I had deposited on the suit property.
10. The applicants have gone ahead to seek order from the Land Registrar to my caveat without
considering my interest the suit land.
11. That to protect my interests, I caveated the said suit land which the 1 st and 2nd applicants are
pressing me to withdraw.
12. That the applicants’ action are unfair, unjust, and intended to jeopardize my rights to the suit
land.
13. That whatever I have stated is true and correct to the best of my knowledge save for
information whose source is disclosed herein.

Sworn at Kampala this November 6, 2023

By the said Kumar Patel ………yyywhs………..
Deponent

Before me
……………………yydufnvn……………………
Commissioner for oaths

DRAWN AND FILED BY

Firm C3&Co.Advocates
LDC Campus, along Gadaffi Road,
Kagugube Road