[2014] KEHC 2343 (KLR)

[2014] KEHC 2343 (KLR)

The court found that the consent order marking the appeal as abated was entered into under a mistake of material fact, namely the presumption that the 2nd appellant was also deceased. In reality, the 2nd appellant was alive, present in court, and had been properly substituted for the deceased 1st appellant. Since...

Source-derived case information.

Citation
[2014] KEHC 2343 (KLR)
Parties
Appellant: Benjamin Machio Lutomia; Appellant: Agneta W. Machio; Respondent: Joseph Isimbishira Wandaka
Court
High Court
Court Station
High Court at Kakamega
Jurisdiction
Kenya
Case Number
Civil Appeal 63 of 1999
Procedural Posture
Civil Appeal / Ruling on Application to Set Aside Consent Order and Revive Appeal
Outcome
Application allowed; consent order set aside; appeal reinstated for hearing.
Judges
SJ Chitembwe
Legal Topics
Abatement of Suit, Consent Orders, Party Substitution, Mistake of Counsel
Source Language
en
Civil Procedure Land and Property Abatement of Suit Consent Orders Party Substitution Mistake of Counsel

Source-derived case record

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Downloadable case file Legal principles 3 Authorities cited 5 Party arguments 2
Sign in to unlock

Parties

Benjamin Machio Lutomia

Appellant

Agneta W. Machio

Appellant

Joseph Isimbishira Wandaka

Respondent

Procedural Posture

Civil Appeal / Ruling on Application to Set Aside Consent Order and Revive Appeal

  1. 1 Whether the consent order marking the appeal as abated should be set aside due to mistake or ignorance of material facts.
  2. 2 Whether the appeal had in fact abated given that the 2nd appellant was alive and had substituted the deceased 1st appellant.

Ratio Decidendi

The court found that the consent order marking the appeal as abated was entered into under a mistake of material fact, namely the presumption that the 2nd appellant was also deceased. In reality, the 2nd appellant was alive, present in court, and had been properly substituted for the deceased 1st appellant. Since abatement only applies where there is no substitution or the party is deceased, and the 2nd appellant was always a party to the proceedings in her own right, the appeal had not abated. The court held that the mistake justified setting aside the consent order to allow the appeal to proceed to a full hearing, thereby upholding the applicant's constitutional right to a fair hearing.

Court Disposition

Application allowed; consent order set aside; appeal reinstated for hearing.

Orders

  • The application dated 7/4/2014 is granted as prayed.
  • The consent order made on 9/2/2012 is hereby set aside.