Mindcaf: Annulation Titre Foncier 1701/Mfoundi Confirmed in Cameroon
Summary
- Célestin Tawamba's SCI Le Neyang is embroiled in a land dispute over property in Yaoundé, registered under title N°1701/Mfoundi since 2016.
- Mme Awapira Crescence Baboke began construction on the property in 2021, having received a provisional concession from Mindcaf for a portion of the land.
- Despite an inter-ministerial consultation confirming SCI Le Neyang's prior title and Mindcaf retracting Baboke's concession in 2024, Baboke continued construction.
- Mindcaf subsequently issued an order on September 3, 2026, declaring the public order nullity of SCI Le Neyang's land title N°1701/Mfoundi.
- Tawamba has appealed to the Prime Minister on September 28, 2026, seeking the revocation of this annulment order, citing concerns about the misuse of state administration.
The Genesis of a Land Dispute
This case underscores the potential vulnerability of registered land titles in Cameroon to administrative decisions, even when seemingly established.
A significant land dispute has emerged in Yaoundé, Cameroon, involving prominent businessman Célestin Tawamba, who serves as the manager of SCI Le Neyang, and Mme Awapira Crescence Baboke, the spouse of the Deputy Director of the Civil Cabinet of the Presidency of the Republic. The core of the conflict centers on an urban property spanning 1003 square meters in the Mfandena area, which SCI Le Neyang has held ownership of since 2015. This property is formally registered under land title N°1701/Mfoundi, a title established following the land's registration in the Mfoundi land registry on April 12, 2016.
The dispute escalated in July 2021 when SCI Le Neyang discovered that Mme Baboke had commenced construction activities on its registered property. In response, SCI Le Neyang promptly sought legal recourse, leading to an urgent referral court issuing Order N°371/HH/Civ on September 28, 2021, which mandated the cessation of all ongoing works. This judicial order was officially served to Mme Baboke on January 13, 2022. It was during these legal proceedings that SCI Le Neyang uncovered a critical administrative action: the Ministry of Domains, Cadastre, and Land Affairs (Mindcaf) had, on April 5, 2021, issued Order N°000130/Mindcaf/Sg/02/1300/1320/NEC. This order granted Mme Baboke a provisional concession for 487 square meters, a portion carved out from the very perimeter of SCI Le Neyang's existing land title N°1701/Mfoundi, despite the property already being titled and registered.
Administrative Reversals and Persistent Challenges
Following the discovery of the provisional concession, SCI Le Neyang initiated a `recours gracieux` with Mindcaf and sought intervention from higher authorities. This led to the Prime Minister ordering an inquiry into the matter. An inter-ministerial consultation, convened on November 30, 2023, subsequently confirmed that the provisional concession granted to Mme Baboke on April 5, 2021, had indeed been issued after the land's initial registration and the establishment of land title N°1701/Mfoundi on April 12, 2016. Consequently, Mindcaf issued an order on February 27, 2024, retracting its earlier Order N°000130, which had granted the provisional concession to Mme Baboke, seemingly reinstating SCI Le Neyang's rights.
Despite this administrative reversal, Mme Baboke reportedly remained on the property and continued her construction project. This compelled SCI Le Neyang to file a new lawsuit with the Tribunal de Grande Instance du Mfoundi (TGI), seeking her expulsion and the demolition of structures erected on its property. However, the situation took another dramatic turn when Mindcaf issued Order N°03292 on September 3, 2026, declaring the `nullité d'ordre public` (public order nullity) of land title N°1701/Mfoundi, which belongs to SCI Le Neyang. This administrative `annulation titre foncier Cameroun` effectively invalidated the company's long-held property rights.
Appeal to the Prime Minister and Broader Concerns
In response to Mindcaf's latest decision, Célestin Tawamba, representing SCI Le Neyang, dispatched a letter to the Prime Minister on September 28, 2026. The correspondence urgently requests the Prime Minister's intervention to revoke Mindcaf Order N°03292, which declared the `Mindcaf arrêté nullité titre foncier 1701/Mfoundi`. Tawamba's letter expresses grave concerns, highlighting that recent developments in this `litige foncier` suggest the state's administrative machinery might be exploited to unlawfully dispossess a private entity of its property rights for the benefit of external interests.
This case underscores the potential vulnerability of registered land titles in Cameroon to administrative decisions, even when seemingly established. Lawyers and compliance officers advising on real estate in Cameroon should be aware of the risks of administrative annulment of titles and the process for challenging such decisions, including appeals to the Prime Minister, to protect client property rights. The ongoing `Célestin Tawamba litige foncier` with `Awapira Crescence Baboke terrain Yaoundé` regarding the `Sci Le Neyang propriété` serves as a stark reminder of the complexities and potential pitfalls in land ownership and administration within the country.
Practical Implications
This case highlights the potential vulnerability of registered land titles in Cameroon to administrative decisions, even when seemingly established. Lawyers and compliance officers advising on real estate in Cameroon should be aware of the risks of administrative annulment of titles and the process for challenging such decisions, including appeals to the Prime Minister, to protect client property rights.
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