[2010] KECA 9 (KLR)

[2010] KECA 9 (KLR)

The court found that the applicant, William Shivachi Miheso, had provided sufficient evidence of the death of Elizabeth Amaiza and his appointment as administrator of her estate. The application for substitution was filed within the 12-month limitation period stipulated by Rule 96(2) of the Court of Appeal Rules. As...

Source-derived case information.

Citation
[2010] KECA 9 (KLR)
Parties
Respondent: Elizabeth Amaiza; Applicant: William Shivachi Miheso; Appellant: Jackson Sabatia Natse; Respondent: The Attorney General; Respondent: The Principal Magistrate’s Kapsabet; Respondent: Kapsabet Land Disputes Tribunal
Court
Court of Appeal
Court Station
Court of Appeal at Kisumu
Jurisdiction
Kenya
Case Number
Civil Appeal (Application) 316 of 2006
Procedural Posture
Civil Appeal / Application for Substitution of Deceased Party
Outcome
application allowed
Legal Topics
Substitution of Parties, Appeal Procedure, Death of Party
Source Language
en
Civil Procedure Substitution of Parties Appeal Procedure Death of Party

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Parties

Elizabeth Amaiza

Respondent

William Shivachi Miheso

Applicant

Jackson Sabatia Natse

Appellant

The Attorney General

Respondent

The Principal Magistrate’s Kapsabet

Respondent

Kapsabet Land Disputes Tribunal

Respondent

Procedural Posture

Civil Appeal / Application for Substitution of Deceased Party

  1. 1 Whether the administrator of the estate of a deceased respondent can be substituted as a party to the appeal within the prescribed limitation period.
  2. 2 Whether the application for substitution was filed within the time stipulated by the Court of Appeal Rules.

Ratio Decidendi

The court found that the applicant, William Shivachi Miheso, had provided sufficient evidence of the death of Elizabeth Amaiza and his appointment as administrator of her estate. The application for substitution was filed within the 12-month limitation period stipulated by Rule 96(2) of the Court of Appeal Rules. As the application was unopposed and all procedural requirements were met, the court allowed the substitution of the applicant in place of the deceased respondent. The court also awarded costs of the application in the appeal to the applicant.

Court Disposition

application allowed

Orders

  • William Shivachi Miheso, administrator of the estate of Elizabeth Amaiza (deceased), is substituted as a party to the appeal in place of the deceased.
  • Costs of the application to be in the appeal.