[2019] KECA 7 (KLR)

[2019] KECA 7 (KLR)

The Court of Appeal held that, following the Supreme Court's decision in Francis Muruatetu & Another v Republic, the mandatory nature of the death sentence imposed under section 296(2) of the Penal Code is unconstitutional. The appellant, having been sentenced to death under this provision, is entitled to have his...

Source-derived case information.

Citation
[2019] KECA 7 (KLR)
Parties
Appellant: David Kiplangat Rono alias Rasta; Respondent: Republic
Court
Court of Appeal
Court Station
Court of Appeal at Nyeri
Jurisdiction
Kenya
Case Number
Criminal Appeal 184 of 2013
Procedural Posture
Criminal Appeal / Appeal From Conviction and Sentence; Remitted for Resentencing
Outcome
Appeal on sentence allowed; matter remitted to High Court for resentencing.
Judges
F Sichale, S ole Kantai
Legal Topics
Robbery With Violence, Mandatory Sentencing, Death Penalty, Constitutional Rights
Source Language
en
Criminal Law Robbery With Violence Mandatory Sentencing Death Penalty Constitutional Rights

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Parties

David Kiplangat Rono alias Rasta

Appellant

Republic

Respondent

Procedural Posture

Criminal Appeal / Appeal From Conviction and Sentence; Remitted for Resentencing

  1. 1 Whether the mandatory death sentence for robbery with violence under section 296(2) of the Penal Code is constitutional in light of recent Supreme Court jurisprudence.
  2. 2 Whether the appellant is entitled to resentencing following the Supreme Court decision in Francis Muruatetu & Another v Republic.

Ratio Decidendi

The Court of Appeal held that, following the Supreme Court's decision in Francis Muruatetu & Another v Republic, the mandatory nature of the death sentence imposed under section 296(2) of the Penal Code is unconstitutional. The appellant, having been sentenced to death under this provision, is entitled to have his sentence reviewed in light of the new jurisprudence. The appropriate course is to remit the matter to the High Court at Kericho for resentencing, where the appellant will have the opportunity to present mitigation and the court will impose a sentence that is just and proportionate to the circumstances of the case.

Court Disposition

Appeal on sentence allowed; matter remitted to High Court for resentencing.

Orders

  • The file is remitted to the High Court at Kericho for resentencing of the appellant.
  • The High Court shall take the appellant's mitigation and award an appropriate sentence.