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Mortgage Law under Transfer of Property Act, 1882 and Shariat Law

 Authors: Faryal Mehmood, Iqra Tanveer,   Hina Shahzadi,   Syeda Sakina Iraqi, Fazila Nawaz and    Fatima Idrees

CHAPTER I

1.     INTRODUCTION

Mortgage is a transfer of an interest in immovable property in order to  securing the payment of money advanced, an existing or future debt which may give rise to a pecuniary liability. If a person wants to obtain loan either from any individual or finical institution or bank. He can go to that person or bank and can get loan by giving a property as a security to that lender. The person who mortgages the property is called mortgagor and the person who receives the property is known as mortgagee.[1]

2.     Historical Background

Ancient roots of mortgage were developed from the English land law in the middle Ages Among the early races of men, loans or favors on properties, must have been by way of pledge rather than by means of a mortgage. Pledge is creating charge over a movable property and mortgage is a charge over immovable property. Hypothecation also emerged which is an agreement, where in a person borrows money from bank by collateralizing an asset without transferring title and possession.[2] First record of a mortgage is found in the sacred writings. The notion of mortgaging lands had origin from the Jews and them the idea of a mortgage passed to the Greeks and Romans, and from them implant upon the Common Law of England. After few cases of mortgage, right developed such as equitable right of redemption.. On default, the mortgagee would seek a court order giving the mortgagor a fixed time perhaps six months or a year within we should pay debt, under court decree. In 1882, mortgage law was codified in Transfer of Property Act.[3]

CHAPTER II

3.     MORTGAGE LAW IN TRANSFER OF PROPERTY ACT, 1882

3.1.   Types of Mortgages

3.1.1.      Simple Mortgage

This is where without delivering possession of mortgaged property, the mortgager binds himself personally to pay the mortgage money and agree by expressly or impliedly that in the event of his failing to pay according to his contract.

3.1.2.      Mortgage by Conditional Sale

In which appears to be sale with a condition that the property sold would be transferred back to original owner on repayment of loan.

3.1.3.      Usufructuary Mortgage

Where the mortgager delivers the possession and right to enjoy an income of and right to enjoy an income and from the property to the mortgagee. If mortgager is not in a position to give immediate possession, it is sufficient if he gives immediate possession.

3.1.4.      English Mortgage

The ownership of property is transferred to the mortgager on one condition that mortgage will transfer ownership on repayment of loan, and the title deeds are transferred to mortgage. [4]

4.     RIGHT AND LIABILITIES OF MORTGAGOR

4.1.   Right to Redeem

According to Section 60 of Transfer of Property Act, mortgagor has the right to redeem the property. The right to redeem the property further awards three rights to the mortgagor:

·         Right to end mortgage deed

·         Right to transfer mortgaged property to his name

·         To take back property in case of transfer of possession[5]

In case of Noakes and Co. v. Rice where a covenant was signed in mortgage deed binding Rice to only sell products of Noakes and Co in its premises. Court held that such a condition is a clog on right of redemption and thus void.[6]

4.2.   Right to Transfer Property to Third Person

Section 60A help the mortgagor to pay off the mortgagee by taking a loan from a third person on the same security and allows him to transfer his property to third person. 

4.3.   Right to Make Copies of Documents

Section 60B provides that mortgagor have the right to ask mortgagee for making the copies of documents of the mortgaged property in his possession. This right is available to the mortgagor only as long as his right to redeem exists.[7] 

4.4.   Right to Accession

Section 63 of transfer of property Act deals with the right of mortgagor, according to this right mortgagor is entitled to any accession to his property which is in the custody of mortgagee.

4.5.   Right to Improvement

Section 63A of transfer of property Act provides that mortgagor has a right to improvement made on his property during its possession by mortgagee in absence of any contract to contrary.

4.6.   Right to Renewed Lease

The mortgaged property is under lease, and the mortgagee during possession of the mortgaged property gets renewal of the lease, then the mortgagor obtain right over benefits of new lease on redemption.[8]

4.7.   Right to Lent Property

According to section 65-A Mortgagor has the right to lease out the mortgaged property while he is in lawful possession of that property with realization of some conditions.[9]

4.8.   Liabilities of Mortgagor

Section 65 provides for certain implied contracts which make mortgagor responsible for certain actions in absence of contract to contrary.  

4.8.1.      Duty to Defend Title

Mortgagor is bound to defend the title of mortgaged property or enable mortgagee to do so same if he has possession of property.

4.8.2.      Duty to Pay Public Charges

Mortgagor is bound to pay all public charges over property if mortgagee is not in possession of property.

4.8.3.      Duty to Direct Rent to Mortgagee

When mortgage is a lease then mortgagor is bound to pay rent reserved by lease, perform conditions of lease and observe contracts binding on lessee and is bound to indemnify mortgagee in case of default in this regard.[10]

5.     RIGHT AND LIABILITIES OF MORTGAGEE

5.1.   Right to Foreclosure or Sale

According to Sec 67, at any time after the mortgage money has been due and before the decree of redemption of the mortgaged property or the mortgage money has been paid, the mortgagee has the right to obtain court decree to debar mortgagor permanently from redeeming property or decree to sale the same.

5.2.   Right to Sue for Mortgage Money

According the Sec 68, the mortgagee has a right to sue for the mortgage-money in the following cases:

a)      Where the mortgagor bind himself for the same repayment;

b)      When the seized property is destroyed wholly or in part without the fault of any party;

c)      When a mortgagee is deprived of all or part of security by misconduct of mortgagor;

d)      Where the mortgagor fails to give possession of property to mortgagee.[11]

5.3.   Right to Accession

According to Sec 70, if after the due date of the mortgage any accession is made to the mortgaged property, the mortgagee will be entitled to that for the purpose of securing his loan.

5.4.   Right to Spend Money

Sec 72 deals with the right of mortgagee in possession to spend money when it is necessary to do so in circumstances like:

a)      Preservation of property seized from destruction, sale or forfeiture;

b)      To defend the title of the mortgagor's property;

c)      For making his own title thereto good against the mortgagor.[12]

5.5.   Liabilities of Mortgagee

According to Sec 76, when during the continuance of the mortgage, the mortgagee takes possession of the mortgaged property, he is bound by the following duties:

a)      The mortgagee has a duty to manage the property as an ordinary prudence person.

b)       Duty of mortgagee to collect rents and profits of the property to this best endeavor.

c)      The mortgagee has a duty to make necessary repairs of the mortgaged property.

d)     The mortgagee has a duty not to commit any act which may destroy or injure the property permanently.

e)      It’s a duty of the mortgagee to apply for insurance money in reinstating the property or in the reduction of the mortgage-money if he receives such money in respect of the mortgaged-property.

f)       He must keep proper, accurate accounts of all sums received and spent by him as a mortgagee.[13]

In case of Panchanan Sharma v. Basudeo Prasad Jaganani, the SC gave a decision based on the specific language of Section 76 (c) of the Transfer of Property Act that the mortgagee was bound to pay the land's income and so on such basis he could not claim that the mortgagor had lost his right to redemption.[14]

6.     DOCTRINE REGULATING MORTGAGE LAW

6.1.   Priority

Section 48 deal with how the conflicting rights created over a particular property can be resolved on the basis of the Doctrine of Priority.[15] Section 48 doesn’t protect or reserve, in favor of a subsequent transferee, even though he has no knowledge of the previous transfer. In Nandkishore v. Harjarilal, the High Court of Madhya Pradesh held that “a transfer cannot prejudice the right of the transferee by any subsequent dealing with the property”.[16]

6.2.   Marshalling Securities

Section 81 provides for the doctrine of marshalling securities which allows a second mortgagee whose debt has not been paid from the sale of mortgaged property to access the proceeds of sale of another property mortgaged by the same debtor to first mortgagee, even though the second mortgagee has primary right over that property. It protects the second mortgagee from decision of first mortgage to sell common mortgaged property in presence of other property.[17]

6.2.1.      Essentials of Marshalling Securities

·         Common Debtor

·         Distinct property

·         No Prejudice to rights of prior Mortgagee[18]

6.3.   Contribution

Section 82 maintains that when more than one mortgagors are there with distinct shares in property mortgaged, each share shall contribute ratable towards the mortgaged debt. Moreover, in case where single mortgagor has mortgaged property to and then mortgages same with another property for another debt. Both properties contribute to debt ratably after deduction of value of debt from the first mortgaged property in absence of contrary contract.[19]

6.3.1.      Limitation of Contribution

Contribution rules do not apply on the property which is liable under section 81 to the claim of the subsequent mortgagee.

6.4.   Subrogation

Subrogation is a right of a person, after paying off his liabilities, to be the place of the creditor. Subrogation takes place only by redemption by persons other than mortgagor who are authorized to do so under section 91. Right of Subrogation is described in Section 92 of the Transfer of Property Act, 1882. The doctrine of subrogation is also based on the principles of good conscience, equity and justice. The principle of the doctrine is that the party who pays off a mortgage gets all the rights of the mortgagee. In order to obtain rights under subrogation, person has to essentially redeem the property fully.[20]

CHAPTER III

7.     MORTGAGE IN ISLAM

Islamic mortgage contract derive its validity from the general Islamic contracts mentioned in Quran. It has not being explicitly mentioned in the primary sources of shariah. The general principles and rules concerning contracts are informed by Quran. Contracts which follow those principles are valid and same are applicable on contracts of mortgage in Islamic finance.[21]  

8.     PRINCIPLES OF ISLAMIC MORTGAGE

Objective of Islamic economic system is to stimulate social justice, equality and better property rights. The Islamic concept asserts that money cannot be made from money, it is only a medium of exchange. Therefore, Shariah has made riba and gharar prohibited in every contract. Riba is unjustified increase of capital in loans or sales and gharar is prohibited for extreme uncertainty in risk of losing or earning the capital.[22] In Quran Allah prohibits such as; “Allah will deprive Riba of all blessing, but will give increase for deeds of charity; for He loved not creatures ungrateful and wicked.”[23]

8.1.   Equity Contracts

8.1.1.      Mudarabah

An agreement made between a party where one person provides the capital and the other invests it in an activity. Profit is distributed according to the pre-determined ratio, yet loss is borne solely by the provider of capital.

8.1.2.      Musharakah

This is a financing partnership where parties provide capital for a project. Profit is shared on pre-agreed ratio but loss on the basis of equity participation.[24]

8.2.   Debt Contracts

8.2.1.      Murabaha

It’s a contract between a financial institute and it client for sale of a good at a price that includes profit margin agreed by both parties. Good are sold with a mark-up and repayments usually in installments are fixed in the contract.

8.2.2.      Ijarah

It is a leasing contract in which a financial institute buys and lease out equipments that are required by clients for a rental fee. Duration of lease and rental fee is decided in advance and ownership remains with the financial institute.[25]

8.2.3.      Ijarah wa Igtina

It is similar to ijarah, except that there is a commitment by the client to buy the equipment at the end of rental period on any price decided by the financial institute, with rental fee previously paid.

8.2.4.      Musharaka wa Iqtina

It implies diminishing partnership. The bank and the customer, in mortgage contract, agree to enter into a partnership and share the same property by two contracts: Ijara contract and Musharaka for specific period. Client pays two kinds of instalments, one to increase the client’s share in the ownership and the other as a rent for the bank’s share. This diminishes the share of the bank and eventually client owns all the property at the end of specified period.[26]

CHAPTER IV

9.     CONCLUSION

It is concluded that in general term the concept of contract is same in both legal systems; English law and Islamic Law. What differentiate both is the subject matter of the contract. Islamic contract should not deal with harmful items such as interest, drugs, alcohol, pork, pornography and gambling etc. Islam does not explicitly define mortgage rules but conventional mortgage system can be analyzed on basis of general rules given by Shariat. Riba is prohibited but in conventional mortgage system there are is no avoidance of such which can be seen in sections of Transfer of property Act, 1882.

Section 58 includes principle money as well as interest in mortgage-money

Section 58(d) allows mortgagee to use benefit of property in lieu of interest

Section 63 binds mortgagor to pay cost of accession as well as interest accruing over it at rate decided for interest over principle sum or in its absence at rat of 9%.

The crucial point of difference between the Islamic and the conventional English mortgage contract is prohibition of Riba (interest), which is not acceptable in Islamic contracts, including mortgage, under any circumstances. 3. The Qur’an does not mention mortgage directly, but the mortgage contract has its roots in the Qur’an within the general theory of the contract. 4. One of the notable differences between the English conventional mortgage contract and the Islamic mortgage contract is that the client under the Islamic mortgage contract can repay the entire sum to the bank at any time before the end of the agreed period without any penalty. This is not allowed under the conventional mortgage.

 





                                 

                                       

                                        

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