MONROVIA, Liberia — The Supreme Court of Liberia has ordered the Liberia Bank for Development and Investment (LBDI) to pay Dr. Togbah Nah Tipoteh US$50,000 in damages, ending a legal dispute stemming from the bank’s failure to return a land deed used as collateral for a loan that had been fully repaid.
The ruling was delivered on August 28, 2026, following arguments before the Supreme Court during its March Term. The case was heard on June 1, with Associate Justice Clinton-Johnson delivering the opinion on behalf of the full bench headed by Chief Justice Yamie Quiqui Gbeisay Sr.
The dispute began after Tipoteh secured a US$10,000 loan from LBDI in November 2015, using the deed to a quarter-acre property on Ashmun Street as collateral.
According to the Court’s findings, Tipoteh settled the loan, including interest and other charges, on March 26, 2016. He subsequently requested the return of his deed, but LBDI failed to release it.
Tipoteh filed an Action of Damages for Wrong before the Sixth Judicial Circuit Civil Law Court in Montserrado County on November 15, 2016. He alleged that the continued retention of the deed caused inconvenience, mental distress and economic hardship and prevented him from using the property for further financial purposes.
The trial court awarded Tipoteh US$200,000 in damages. LBDI appealed the decision to the Supreme Court.
While the Supreme Court agreed that damages were warranted, it reduced the award to US$50,000, finding that Tipoteh had not provided sufficient evidence to establish the full extent of the economic losses alleged.
The Court relied on established Liberian jurisprudence requiring parties seeking general damages to present evidence demonstrating the nature and magnitude of the injuries suffered.
Of the final award, US$35,000 represents general damages, while US$15,000 was imposed as punitive damages for what the Court described as LBDI’s “wanton and reckless act” in failing to return the deed.
The Supreme Court also directed its Clerk to issue a mandate to the Sixth Judicial Circuit Civil Law Court, instructing the lower court to resume jurisdiction and enforce the judgment.
The decision brings to a close a dispute that remained before the courts for nearly a decade and provides a significant ruling on the obligations of financial institutions concerning collateral after a borrower’s debt has been fully discharged.
