A Caribbean Court of Justice judgment on a handwritten receipt, and the commencement of the Sea and River Defence Act 2024, are the developments of the past month that will most immediately affect those who deal in, lend against or occupy land in Guyana.
The National Assembly passed no new Act in the month to mid-November. On 11 November it gave a first reading to four Bills and referred a fifth to a special select committee. Those proposals will repay close watching, but they are not yet law. Two developments already are: a unanimous judgment of the Caribbean Court of Justice on informal writings about land, and the long-delayed commencement of the Sea and River Defence Act 2024.
On 3 November the Court delivered judgment in Janet Hassan v Romanie Gouveia [2026] CCJ 16 (AJ) GY. A handwritten receipt of 24 May 1990, signed by Eric Sue, recorded “Full Payment” of $2,235 by Abdool Hassan “for the use of” a parcel at Plot B, Spring Garden, Essequibo Coast, “on the understanding that no transport can be issued”, and contemplated the erection of houses. The High Court treated the receipt as authentic evidence of a contract for sale and dismissed a claim for possession. The Court of Appeal read it as a mere licence. The Caribbean Court of Justice allowed the appeal and restored the trial judge’s order.
The reasoning will travel well beyond these facts. Following its decisions in Insurance Corp of Belize Ltd v Kahtal Resorts International Ltd and Blairmont Rice Investment Inc v Kayman Sankar Investments Ltd, the Court held that a written document is to be read objectively, as a whole, in its factual, contractual and textual contexts — a question of mixed law and fact. Particular phrases — “for the use of”, “no transport can be issued” — could not be isolated from that setting. Informal receipts remain common in Guyana. They will not be dismissed as licences merely because they are inelegant or decline to promise a transport. Nor should they be assumed to perfect a title. The Court was not asked to decide whether the later transport should be challenged, or whether a claim for specific performance would lie.
The judgment has a second holding of general importance. The Court of Appeal, having granted leave to appeal, awarded costs of $300,000 on a routine and only partly successful application — more than on the substantive appeal — and gave no reasons. The Caribbean Court of Justice set the award aside. A costs discretion is judicial; reasons ought generally to be given; and a significantly disproportionate or arbitrary costs order can undermine the constitutional guarantees of access to justice, a fair hearing, and protection from the unlawful deprivation of property. The sum is to be repaid by 3 December 2026.
The second development already in force is statutory. By Order No. 188 of 2026, the Sea and River Defence Act 2024 (Commencement) Order 2026, made on 7 October by the Minister of Public Works under section 2 and published in the Official Gazette of 17 October, 7 October 2026 was appointed as the day on which the Sea and River Defence Act 2024, Act No. 9 of 2024, came into operation. Passed on 17 May 2024 and gazetted on 24 May 2024, the Act had waited more than two years. It repeals and replaces the existing sea-defence legislation. It constitutes a Sea and River Defence Board; provides for national and local defences and for natural defences, including the planting of mangroves; creates waterfront development zones; empowers authorised officers to enter land; and provides for flood protection notices, which a new occupier takes on, together with offences and administrative penalties. Due diligence on coastal and riverine land should now take in those notices, restrictions on alteration without the Board’s permission, and the Board’s planning and enforcement powers.
Also this month
Four Bills published on 10 November received a first reading the next day. The National Heritage Preservation Bill 2026 (Bill No. 16) would establish a National Heritage Preservation Council and provide for the designation of sites, districts, objects, underwater heritage and treasure trove, with duties on owners, planning permits, heritage preservation orders and compulsory acquisition. The Telehealth and Digital Health Services Bill 2026 (Bill No. 15) would regulate remote care, including transfers of patient information outside Guyana and the use of artificial intelligence in health. Bills on emergency medical services (Bill No. 14) and alternative sentencing (Bill No. 17), the latter repealing the Extra-Mural Work Act, Cap. 11:02, were also introduced. The same sitting referred the Gaming Authority Bill 2026 (Bill No. 12 of 2026) to a special select committee. The Department of Public Information reports that the Bill would create an authority to license, supervise, tax and enforce across casinos, gaming lounges, betting shops, remote gaming and simulcast horse racing, with anti-money-laundering measures.
Of immediate effect, Order No. 196 of 2026, the Customs (Amendment of Second Schedule) Order 2026, made on 10 November under section 43(2) of the Customs Act, adds vaping products to the list of restricted imports, except with the written approval of the Minister of Health for scientific research, training or a medical purpose. Order No. 189 of 2026, published on 24 October, declares compulsory LPG cylinder and regulator standards, to be enforced from 1 April 2027. And in the Official Gazette of 31 October, the Bank of Guyana designated the Guyana Development Bank a credit information provider under the Credit Reporting Act 2010.
Bills at first reading may change, and some may wait. The judgment and the commencement order already bind. In a country where much land still changes hands on informal paper, and where so much of the economy sits behind a sea wall, those are the developments of the month that practitioners, lenders and investors should read first.