[2011] KEHC 736 (KLR)

[2011] KEHC 736 (KLR)

The court found that there is no requirement under Order 16 Rule 6 for a formal application for summons to produce documents. The demand for a formal application was deemed a delaying tactic. The court relied on its discretionary powers under Sections 3A and 3B of the Civil Procedure Act and Article 159 of the...

Source-derived case information.

Citation
[2011] KEHC 736 (KLR)
Parties
Plaintiff: Consolidated Bank of Kenya Limited; Defendant: Pan African Insurance Co. Limited
Court
High Court
Court Station
High Court at Nairobi (Milimani Commercial Courts)
Jurisdiction
Kenya
Case Number
Civil Case 478 of 2003
Procedural Posture
Civil Case / Ruling on Oral Application for Summons to Produce Documents
Outcome
application granted
Judges
DO Ogembo
Legal Topics
Discovery of Documents, Court Discretion, Mergers and Acquisitions
Source Language
en
Civil Procedure Commercial and Corporate Discovery of Documents Court Discretion Mergers and Acquisitions

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Summary, issues, holding and outcome

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Parties

Consolidated Bank of Kenya Limited

Plaintiff

Pan African Insurance Co. Limited

Defendant

Procedural Posture

Civil Case / Ruling on Oral Application for Summons to Produce Documents

  1. 1 Whether the court can grant an oral application for summons to produce documents under Order 16 Rule 6 without a formal application.
  2. 2 Whether the Registrar of Companies should be compelled to produce documents relating to the alleged merger between Pan African Insurance Co. Ltd. and Apollo Insurance Co. Ltd.

Ratio Decidendi

The court found that there is no requirement under Order 16 Rule 6 for a formal application for summons to produce documents. The demand for a formal application was deemed a delaying tactic. The court relied on its discretionary powers under Sections 3A and 3B of the Civil Procedure Act and Article 159 of the Constitution to dispense justice without undue regard to technicalities. Consequently, the court granted the oral application and ordered the Registrar of Companies to produce the requested documents for inspection by the Plaintiff's advocates.

Court Disposition

application granted

Orders

  • The Registrar of Companies is compelled to produce for inspection by Oraro & Company Advocates for the Plaintiff the file relating to APA Insurance Company Limited and furnish any documents, evidence, and information relating to the alleged merger between Pan African Insurance Co. Ltd. and Apollo Insurance Company...
  • The Registrar of Companies is ordered to comply within seven (7) days of service of the order.