Question

Difficulty: MediumSale of Goods Act: Transfer of Title, Delivery, and Buyer/Seller Remedies

Emeka obtained a refrigerator from a commercial store under a hire purchase agreement. Before paying the final installment required to complete the purchase, Emeka sold the refrigerator to Grace, who bought it in good faith without knowledge of the agreement. Under the Sale of Goods Act, why does Grace NOT acquire a valid legal title to the refrigerator?

  1. Emeka was not the legal owner at the time of sale and could not pass a better title than he possessed.Answer
  2. B
    Hire purchase agreements automatically transfer legal ownership to the buyer immediately upon signing the contract.
  3. C
    Grace breached an essential condition of the original commercial sales contract between Emeka and the store.
  4. D
    The store's initial display of the refrigerator created a binding legal offer directly to Grace rather than an invitation to treat.

Answer

Grace does not acquire valid title because Emeka was not the legal owner of the refrigerator at the time of the sale and could not transfer a better title than he possessed under the rule of Nemo Dat Quod Non Habet.
The correct option correctly applies the fundamental legal maxim 'nemo dat quod non habet' (no one can give what he does not have). Under a hire purchase agreement, title to the goods remains with the owner/dealer until the final installment is paid. Because Emeka sold the refrigerator before paying the final installment, he had no title to pass to Grace.

Step-by-Step Solution

1
Analyze the nature of the contract between Emeka and the store.
Under a hire purchase contract, ownership (title) remains with the seller/lessor until the final installment is fully paid.
Hire purchase is a hiring agreement with an option to buy upon final payment.
2
Apply the rule of transfer of title under the Sale of Goods Act.
Since Emeka had not made the final installment, he possessed only custody, not ownership.
The fundamental legal principle 'nemo dat quod non habet' dictates that a person cannot give what they do not have.
3
Evaluate the third-party purchaser's legal position.
Grace does not receive valid title to the refrigerator despite buying in good faith.
No statutory exception to nemo dat applies because Emeka was a hirer, not a buyer who had acquired ownership or sold under a credit sale.

Key Concept

Nemo Dat Quod Non Habet and Transfer of Title in Sale of Goods
Estimated Time:1m 0s
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