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Wednesday, 23 April 2014

In case of encumbrance, burden shifts from person to property

A mere burden on a person or obligor is not an encumbrance. Needless to say, every 
person who has an obligation to pay money is expected to have assets to pay the 
same. If all the lender is expecting is that the obligor will pay money and will have 
enough assets to pay the same, it is not a case of encumbrance. In case of 
encumbrance, the burden shifts from the person to the property – and the burden 
travels with the property.
One of the most characteristic features of encumbrance 
would be that the encumbrancer will not be free to deal with the property in the 
way he likes. Second, the lender will have a right over the property, so as to extract 
money from the property if the personal obligation fails. 

A mere restraint on the owner of property that he will not alienate his property 
cannot be said to be an encumbrance. If that were so, every obligation to pay money 
will amount to an encumbrance because in every obligation, the creditor expects 
that the debtor will not alienate property or deal with it to the detriment of the 
creditor. 

The following important features of encumbrances arise from the discussion above: 
• An encumbrance is a burden attached to property; 
• If it is a burden for the owner, it must be a benefit for the person holding the 
encumbrance. This also follows from the discussion by Salmond which has 
taken encumbrances to be jura in re propria, that is, rights over estate of 
someone else. That is, the burden created by the owner must be such which 
can operate as a benefit in the hands of the person holding the encumbrance. 
• The burden must necessarily be attached to the asset in question. 
Since the essence of attachment or concurrence of the burden is that the 
burden will pass on a person acquiring the property, it necessarily follows 
that the burden must be on an ascertainable, identifiable property.
 • A mere restraint on sale or negative covenant is not an encumbrance.
leading English case law on whether a negative covenants “runs” with the 
property is Tulk v Moxhay (1848) 41 ER 1143. This classic ruling holds that a 
negative covenant is passable to the buyer of the property only where the 
parties intended the same to pass, and the burden “touches and concerns” 
the property. Here, a question of intent of parties will come in. 

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