[2025] KEHC 9285 (KLR)

[2025] KEHC 9285 (KLR)

The High Court lacks jurisdiction to entertain an application seeking to substitute a sentence that has already been determined and imposed by the Court of Appeal. Once the appellate court has rendered its decision on sentence, the High Court cannot revisit or alter that sentence, as doing so would amount to sitting...

Source-derived case information.

Citation
[2025] KEHC 9285 (KLR)
Parties
Applicant: Samuel Omondi Gombe alias Agok; Applicant: Vitalis Obula Okendo alias Daktari; Applicant: Hezron Otieno Okendo alias Otis; Respondent: Republic
Court
High Court
Court Station
High Court at Kisumu
Jurisdiction
Kenya
Judgment Date
30 June 2025
Case Number
Criminal Miscellaneous Application E233 of 2024
Procedural Posture
Criminal Miscellaneous Application / Ruling on Application to Substitute Custodial Sentence With Non Custodial Sentence
Outcome
application dismissed for want of jurisdiction
Judges
A Mabeya
Legal Topics
Murder Sentencing, Jurisdiction of High Court, Sentence Substitution, Appellate Review
Source Language
english
Criminal Law Murder Sentencing Jurisdiction of High Court Sentence Substitution Appellate Review

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Parties

Samuel Omondi Gombe alias Agok

Applicant

Vitalis Obula Okendo alias Daktari

Applicant

Hezron Otieno Okendo alias Otis

Applicant

Republic

Respondent

Procedural Posture

Criminal Miscellaneous Application / Ruling on Application to Substitute Custodial Sentence With Non Custodial Sentence

  1. 1 Does the High Court have jurisdiction to substitute a sentence imposed by the Court of Appeal with a non-custodial sentence?
  2. 2 Can the applicants' custodial sentence of 15 years be substituted with a non-custodial sentence for the same period?

Ratio Decidendi

The High Court lacks jurisdiction to entertain an application seeking to substitute a sentence that has already been determined and imposed by the Court of Appeal. Once the appellate court has rendered its decision on sentence, the High Court cannot revisit or alter that sentence, as doing so would amount to sitting on appeal over the appellate court's decision, which is impermissible under the doctrine of hierarchy of courts and the principle that jurisdiction must be expressly conferred by law. The applicants' motion is therefore dismissed for want of jurisdiction.

Court Disposition

application dismissed for want of jurisdiction

Orders

  • The application to substitute the 15-year custodial sentence with a non-custodial sentence is dismissed.
  • The High Court has no jurisdiction to entertain the motion.