Land & property / Guyana / Judgment report
CCJ restores defence to Guyana possession claim after examining handwritten receipt
The court treated an informal land receipt as evidence of a sale agreement and overturned a separate costs order. Its decision did not order a transfer of title.
A decades-old handwritten receipt has helped Janet Hassan defeat a claim for possession of land in Guyana. In a judgment delivered on 3 November, the Caribbean Court of Justice restored the trial court’s dismissal of the claim brought by Romanie Gouveia.
The dispute concerned land at Spring Garden on the Essequibo Coast. A 1990 receipt acknowledged a payment by Hassan’s husband. Its wording referred to use of the land and an inability to issue a transport, but also recorded full payment and contemplated construction of a home. A transport is a Guyanese title instrument.
The court read the document against the transaction’s circumstances rather than treating any single phrase as decisive. It concluded that the receipt evidenced a sale agreement. That reversed the Court of Appeal’s treatment of the arrangement as a licence to occupy.
The CCJ also set aside a GYD300,000 costs order made on the application for leave to appeal. The unexplained order arose from a routine application that had partly succeeded. Gouveia must repay that sum by 3 December 2026 and pay the costs specified in the final order.
The boundaries of the ruling matter. The court did not decide issues about challenging Gouveia’s transport or the absence of a counterclaim for specific performance. It did not order title to be transferred.
A Guyana domestic appeal concerning the interpretation of a land receipt and a separate costs order. The judgment was delivered on 3 November and announced by the court on 4 November. Its reasoning is comparative for Jamaica; local formalities and registration rules require separate checking.
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