[2008] KEHC 2769 (KLR)

[2008] KEHC 2769 (KLR)

The court found that the applicants had demonstrated sufficient interest and a prima facie arguable case, justifying the grant of leave to commence judicial review proceedings. However, the court held that the law does not permit the grant of stay orders in the nature of mandamus at the leave stage, as stay orders...

Source-derived case information.

Citation
[2008] KEHC 2769 (KLR)
Parties
Applicant: Ephantus Nyaga Ngiri; Applicant: Daniel Karanja Njuguna; Applicant: Japheth Mugambi Arthur; Applicant: Zablon Mwangi Kariuki; Applicant: Francis Njeru Njogu; Applicant: John Njagi Michael; Applicant: Esther Mumbi Maina; Respondent: Horticultural Crops Development Authority; Respondent: Commissioner of Customs & Excise
Court
High Court
Court Station
High Court at Nairobi (Milimani Commercial Courts)
Jurisdiction
Kenya
Case Number
Miscellaneous Civil Application 214 of 2008
Procedural Posture
Miscellaneous Application / Application for Leave to Commence Judicial Review Proceedings
Outcome
leave granted to file judicial review; stay orders declined
Judges
GMA Dulu
Legal Topics
Judicial Review, Mandamus, Prohibition, Leave to Apply, Public Authority Duties
Source Language
en
Administrative Law Civil Procedure Judicial Review Mandamus Prohibition Leave to Apply Public Authority Duties

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Parties

Ephantus Nyaga Ngiri

Applicant

Daniel Karanja Njuguna

Applicant

Japheth Mugambi Arthur

Applicant

Zablon Mwangi Kariuki

Applicant

Francis Njeru Njogu

Applicant

John Njagi Michael

Applicant

Esther Mumbi Maina

Applicant

Horticultural Crops Development Authority

Respondent

Commissioner of Customs & Excise

Respondent

Procedural Posture

Miscellaneous Application / Application for Leave to Commence Judicial Review Proceedings

  1. 1 Whether the applicants have sufficient interest and an arguable case to warrant leave to commence judicial review proceedings.
  2. 2 Whether leave granted can operate as a stay in the nature of mandamus, compelling the respondents to perform statutory duties.
  3. 3 Whether the court can grant interim orders of mandamus at the leave stage.

Ratio Decidendi

The court found that the applicants had demonstrated sufficient interest and a prima facie arguable case, justifying the grant of leave to commence judicial review proceedings. However, the court held that the law does not permit the grant of stay orders in the nature of mandamus at the leave stage, as stay orders are only available for applications for prohibition or certiorari. Granting a stay in the form of mandamus would amount to issuing interim orders compelling a public authority to perform its statutory functions, which is not allowed under Order 53 rule 1(4) of the Civil Procedure Rules. Accordingly, leave was granted, but the request for stay was declined.

Court Disposition

leave granted to file judicial review; stay orders declined

Orders

  • Chamber summons dated 22nd April 2008 certified as urgent.
  • Leave granted to the applicants to file judicial review proceedings as requested under prayer 2 and 3 of the Chamber Summons. The main motion to be filed within 21 days.