[2021] KEHC 8450 (KLR)

[2021] KEHC 8450 (KLR)

The court held that the mandatory death sentence for robbery with violence under section 296(2) of the Penal Code is unconstitutional, applying the Supreme Court's reasoning in Muruatetu. The court exercised its discretion to re-sentence the appellant, considering the aggravating circumstances (rape committed during...

Source-derived case information.

Citation
[2021] KEHC 8450 (KLR)
Parties
Appellant: David Mwangi Waigwa; Respondent: Republic
Court
High Court
Court Station
High Court at Nyeri
Jurisdiction
Kenya
Case Number
Criminal Appeal 45 of 2006
Procedural Posture
Criminal Appeal / Re Sentencing Ruling After Supreme Court Decision and Prior Appeals Dismissed
Outcome
Sentence of death set aside; appellant re-sentenced to 25 years imprisonment on each count, sentences to run concurrently from original sentencing date.
Judges
DW Mbuteti
Legal Topics
Robbery With Violence, Rape, Sentencing Principles, Mandatory Sentences, Resentencing, Constitutional Rights
Source Language
en
Criminal Law Robbery With Violence Rape Sentencing Principles Mandatory Sentences Resentencing Constitutional Rights

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Parties

David Mwangi Waigwa

Appellant

Republic

Respondent

Procedural Posture

Criminal Appeal / Re Sentencing Ruling After Supreme Court Decision and Prior Appeals Dismissed

  1. 1 Whether the mandatory death sentence for robbery with violence under section 296(2) of the Penal Code is unconstitutional following the Supreme Court decision in Muruatetu.
  2. 2 Whether the appellant is entitled to re-sentencing in light of the Supreme Court's decision.
  3. 3 What is the appropriate sentence for the appellant given the circumstances of the offences and his personal circumstances.

Ratio Decidendi

The court held that the mandatory death sentence for robbery with violence under section 296(2) of the Penal Code is unconstitutional, applying the Supreme Court's reasoning in Muruatetu. The court exercised its discretion to re-sentence the appellant, considering the aggravating circumstances (rape committed during the robbery, use of a weapon to threaten the victim, lack of remorse) and mitigating factors (first offender, favourable probation report, time spent in custody). The court found that the death sentence and life imprisonment were not suitable in the circumstances and substituted both sentences with 25 years imprisonment each, to run concurrently from the original sentencing date.

Court Disposition

Sentence of death set aside; appellant re-sentenced to 25 years imprisonment on each count, sentences to run concurrently from original sentencing date.

Orders

  • The sentence of death in count I is set aside and substituted with imprisonment for twenty-five (25) years.
  • For count II, the appellant is sentenced to twenty-five (25) years imprisonment.