[2023] KEELC 15965 (KLR)

[2023] KEELC 15965 (KLR)

The court found that the appellant had demonstrated sufficient grounds for substituted service, namely the death of the respondents' advocate, the absence of any notice of change of advocate or intention to act in person by the respondents, and the inability to trace the respondents. The court relied on Order 5 Rule...

Source-derived case information.

Citation
[2023] KEELC 15965 (KLR)
Parties
Appellant: Construction Group Company Limited; Respondent: Anyango Ogada (Suing as the legal representative of the Estate of Debora Owande Ogada (Deceased)); Respondent: Sam Onyango Ogada; Respondent: Agnes Atieno Otieno
Court
Environment and Land Court
Court Station
Environment and Land Court at Homa Bay
Jurisdiction
Kenya
Case Number
Environment and Land Appeal 29 of 2021
Procedural Posture
Environment and Land Appeal / Ruling on Application for Substituted Service
Outcome
Application for substituted service allowed.
Judges
GMA Ongondo
Legal Topics
Substituted Service, Service of Process, Appeals Procedure, Estate Disputes
Source Language
en
Civil Procedure Land and Property Substituted Service Service of Process Appeals Procedure Estate Disputes

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Parties

Construction Group Company Limited

Appellant

Anyango Ogada (Suing as the legal representative of the Estate of Debora Owande Ogada (Deceased))

Respondent

Sam Onyango Ogada

Respondent

Agnes Atieno Otieno

Respondent

Procedural Posture

Environment and Land Appeal / Ruling on Application for Substituted Service

  1. 1 Whether the appellant should be allowed to serve the respondents by substituted service due to inability to trace them and the death of their advocate.

Ratio Decidendi

The court found that the appellant had demonstrated sufficient grounds for substituted service, namely the death of the respondents' advocate, the absence of any notice of change of advocate or intention to act in person by the respondents, and the inability to trace the respondents. The court relied on Order 5 Rule 17 of the Civil Procedure Rules, 2010, which provides for substituted service when personal service is impracticable, and cited the importance of service as established in Baiywa v Bach (1987) KLR 89. The court also considered constitutional provisions on access to justice and fair hearing, as well as statutory provisions empowering the court to make orders for the just...

Court Disposition

Application for substituted service allowed.

Orders

  • The appellant's counsel shall serve the respondents by substituted service within thirty days from the date of the ruling.
  • The appeal is set for April 17, 2023 to confirm compliance and for directions.