[2024] KEHC 1264 (KLR)

[2024] KEHC 1264 (KLR)

The court held that the omission to award costs in the judgment does not constitute an error apparent on the face of the record. The court reasoned that the award of costs is a discretionary matter, and any alleged error in the exercise of that discretion is a question of law that should be addressed through an...

Source-derived case information.

Citation
[2024] KEHC 1264 (KLR)
Parties
Applicant: AM (Suing Through Next Friend and Father JA); Respondent: Michael Muema Kimilu
Court
High Court
Court Station
High Court at Kakamega
Jurisdiction
Kenya
Case Number
Civil Appeal 107 of 2018
Procedural Posture
Civil Appeal / Ruling on Application for Review of Judgment
Outcome
Application for review dismissed with costs to the respondent.
Judges
PJO Otieno
Legal Topics
Review of Judgment, Error Apparent on Face of Record, Award of Costs, Discretion of Court
Source Language
en
Civil Procedure Review of Judgment Error Apparent on Face of Record Award of Costs Discretion of Court

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Parties

AM (Suing Through Next Friend and Father JA)

Applicant

Michael Muema Kimilu

Respondent

Procedural Posture

Civil Appeal / Ruling on Application for Review of Judgment

  1. 1 Whether the omission to award costs in the judgment constitutes an error apparent on the face of the record warranting review.
  2. 2 Whether the appropriate remedy for failure to award costs is review or appeal.

Ratio Decidendi

The court held that the omission to award costs in the judgment does not constitute an error apparent on the face of the record. The court reasoned that the award of costs is a discretionary matter, and any alleged error in the exercise of that discretion is a question of law that should be addressed through an appeal, not by way of review. The court relied on binding appellate authority to distinguish between errors that may be corrected on review and those that are properly the subject of an appeal. Consequently, the application for review was dismissed as it did not meet the threshold for review under Order 45 Rule 1 of the Civil Procedure Rules and section 80 of the Civil Procedure Act.

Court Disposition

Application for review dismissed with costs to the respondent.

Orders

  • The application dated 21.7.2023 is dismissed with costs.