[2025] KEHC 8207 (KLR)

[2025] KEHC 8207 (KLR)

The court found that the applicant had established a prima facie case that the assets sought to be preserved were likely proceeds of crime, given the evidence of funds obtained by false pretences and the subsequent deposit and use of those funds in the acquisition of vehicles and placement in bank accounts. The 1st...

Source-derived case information.

Citation
[2025] KEHC 8207 (KLR)
Parties
Applicant: Assets Recovery Agency; Respondent: Jean Emmanuel Marlon; Respondent: Winnie Muthoni Maina; Respondent: Afrex Connections Limited; Respondent: Skydive Rhino Kenya Limited-Curlcy; Respondent: Rhino Prime Metal Interantiona Ltd-Curlcy
Court
High Court
Court Station
High Court at Nairobi (Milimani Law Courts)
Jurisdiction
Kenya
Case Number
Anti-corruption and Economic Crimes Miscellaneous E023 of 2025
Procedural Posture
Miscellaneous Application / Ruling on Preservation Application
Outcome
Preservation orders granted in respect of the listed assets; transfer of funds to applicant's account declined as premature; no order as to costs.
Judges
BM Musyoki
Legal Topics
Proceeds of Crime, Asset Preservation Orders, Money Laundering, Forfeiture Proceedings, False Pretences, Bank Account Freezing
Source Language
en
Criminal Law Civil Procedure Banking and Finance Proceeds of Crime Asset Preservation Orders Money Laundering Forfeiture Proceedings False Pretences +1 more

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Parties

Assets Recovery Agency

Applicant

Jean Emmanuel Marlon

Respondent

Winnie Muthoni Maina

Respondent

Afrex Connections Limited

Respondent

Skydive Rhino Kenya Limited-Curlcy

Respondent

Rhino Prime Metal Interantiona Ltd-Curlcy

Respondent

Procedural Posture

Miscellaneous Application / Ruling on Preservation Application

  1. 1 Whether the assets in question are proceeds of crime and liable to preservation under the Proceeds of Crime and Anti-Money Laundering Act.
  2. 2 Whether the applicant has established sufficient grounds for the preservation of the listed assets pending forfeiture proceedings.
  3. 3 Whether the funds should be transferred to the applicant's Criminal Assets Fund Account at this stage.

Ratio Decidendi

The court found that the applicant had established a prima facie case that the assets sought to be preserved were likely proceeds of crime, given the evidence of funds obtained by false pretences and the subsequent deposit and use of those funds in the acquisition of vehicles and placement in bank accounts. The 1st respondent's status as a foreign national with multiple identities increased the risk of asset dissipation, justifying the need for preservation. However, the court held that the request to transfer the preserved funds to the applicant's Criminal Assets Fund Account was premature, as preservation suffices to secure the assets pending the outcome of forfeiture proceedings. The...

Court Disposition

Preservation orders granted in respect of the listed assets; transfer of funds to applicant's account declined as premature; no order as to costs.

Orders

  • Motor vehicles registration numbers KCW 8X0M and KDJ 03XQ are preserved for ninety days upon publication in the Gazette.
  • Motor cycles registration numbers KMEG 4X8M and KMGH 23XF are preserved for ninety days upon publication in the Gazette.