[2014] KEHC 7286 (KLR)

[2014] KEHC 7286 (KLR)

The court held that the provisions of Order 32 rule 2(1) of the Civil Procedure Rules are mandatory and require that suits involving minors be brought as representative actions by adults. Since the suit in the children's court was not brought in compliance with this requirement, it was incompetent. The paramountcy...

Source-derived case information.

Citation
[2014] KEHC 7286 (KLR)
Parties
Appellant: D M; Respondent: G G
Court
High Court
Court Station
High Court at Nairobi (Milimani Commercial Courts)
Jurisdiction
Kenya
Case Number
Civil Appeal 77 of 2011
Procedural Posture
Civil Appeal / Judgment
Outcome
appeal dismissed
Judges
DN Musyoka
Legal Topics
Children Suits, Representative Actions, Capacity to Sue
Source Language
english
Family and Children Civil Procedure Children Suits Representative Actions Capacity to Sue

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Parties

D M

Appellant

G G

Respondent

Procedural Posture

Civil Appeal / Judgment

  1. 1 Whether the suit in the children's court was incompetent for failure to comply with Order 32 rule 2(1) of the Civil Procedure Rules regarding representative suits for minors.
  2. 2 Whether non-compliance with mandatory procedural requirements can be cured by the paramountcy of the child's welfare.

Ratio Decidendi

The court held that the provisions of Order 32 rule 2(1) of the Civil Procedure Rules are mandatory and require that suits involving minors be brought as representative actions by adults. Since the suit in the children's court was not brought in compliance with this requirement, it was incompetent. The paramountcy of the child's welfare cannot cure the fundamental defect of lack of capacity to sue. Accordingly, the appeal lacked merit and was dismissed.

Court Disposition

appeal dismissed

Orders

  • The appeal is dismissed.
  • Costs shall go to the respondent.