[2018] KEHC 9253 (KLR)

[2018] KEHC 9253 (KLR)

The court found that while the trial magistrate imposed a fine rather than a custodial sentence, the default custodial sentence for non-payment of the fine did not comply with Section 28(2) of the Penal Code. The court substituted the default sentence with 12 months imprisonment in default of payment of the fine....

Source-derived case information.

Citation
[2018] KEHC 9253 (KLR)
Parties
Applicant: Charles Nyairo Abisi; Respondent: Republic
Court
High Court
Court Station
High Court at Nairobi (Milimani Law Courts)
Jurisdiction
Kenya
Case Number
Criminal Revision 5 of 2018
Procedural Posture
Criminal Revision / Ruling on Application for Revision of Sentence
Outcome
application dismissed with variation of sentence and imposition of mandatory licence disqualification
Legal Topics
Sentencing Principles, Dangerous Driving, Traffic Offences, Revision Jurisdiction
Source Language
en
Criminal Law Sentencing Principles Dangerous Driving Traffic Offences Revision Jurisdiction

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Summary, issues, holding and outcome

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Parties

Charles Nyairo Abisi

Applicant

Republic

Respondent

Procedural Posture

Criminal Revision / Ruling on Application for Revision of Sentence

  1. 1 Whether the sentence imposed on the Applicant for causing death by dangerous driving was excessive or unlawful.
  2. 2 Whether the Applicant is entitled to a non-custodial sentence or reduction of the fine imposed.
  3. 3 Whether the Applicant's driving licence should be reinstated or the period of disqualification reviewed.

Ratio Decidendi

The court found that while the trial magistrate imposed a fine rather than a custodial sentence, the default custodial sentence for non-payment of the fine did not comply with Section 28(2) of the Penal Code. The court substituted the default sentence with 12 months imprisonment in default of payment of the fine. The court also noted that the trial magistrate failed to disqualify the Applicant from holding or applying for a driving licence for three years as required by Section 46 of the Traffic Act. Accordingly, the court ordered the mandatory three-year disqualification to commence upon completion of the sentence. The court considered the Applicant's personal circumstances but held that...

Court Disposition

application dismissed with variation of sentence and imposition of mandatory licence disqualification

Orders

  • The sentence is set aside and substituted with a fine of Ksh. 400,000, in default 12 months imprisonment.
  • The Applicant is disqualified from holding or applying for a driving licence for three years commencing upon completion of his sentence.