[2020] KEHC 7208 (KLR)

[2020] KEHC 7208 (KLR)

The court found that the Respondents had not issued a tax demand, the amount of tax due was undetermined, and there was no evidence that the petitioner was a flight risk or lacked a known place of residence. The Respondents admitted the investigation was ongoing and no demand letter had been issued. The court held...

Source-derived case information.

Citation
[2020] KEHC 7208 (KLR)
Parties
Petitioner: Hassan Adan Bare; Respondent: Kenya Revenue Authority; Respondent: The Hon. Attorney General
Court
High Court
Court Station
High Court at Nairobi (Milimani Law Courts)
Jurisdiction
Kenya
Case Number
Petition 45 of 2020
Procedural Posture
Constitutional Petition / Ruling on Interlocutory Application for Conservatory Orders
Outcome
Application allowed; conservatory order granted suspending DPO subject to conditions.
Judges
AN Makau
Legal Topics
Departure Prohibition Orders, Fair Administrative Action, Tax Investigations, Right to Movement, Prima Facie Case
Source Language
en
Constitutional Law Tax Law Civil Procedure Departure Prohibition Orders Fair Administrative Action Tax Investigations Right to Movement Prima Facie Case

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Summary, issues, holding and outcome

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Parties

Hassan Adan Bare

Petitioner

Kenya Revenue Authority

Respondent

The Hon. Attorney General

Respondent

Procedural Posture

Constitutional Petition / Ruling on Interlocutory Application for Conservatory Orders

  1. 1 Whether the issuance of a Departure Prohibition Order (DPO) against the petitioner without a tax demand or determination violates the Constitution and statutory law.
  2. 2 Whether the Respondents' actions contravened the petitioner's right to fair administrative action under Article 47 of the Constitution and the Fair Administrative Action Act.
  3. 3 Whether the petitioner has established a prima facie case to warrant the grant of conservatory orders suspending the DPO.

Ratio Decidendi

The court found that the Respondents had not issued a tax demand, the amount of tax due was undetermined, and there was no evidence that the petitioner was a flight risk or lacked a known place of residence. The Respondents admitted the investigation was ongoing and no demand letter had been issued. The court held that the issuance of the DPO without these prerequisites violated section 45 of the Tax Procedures Act and the petitioner's right to fair administrative action under Article 47 of the Constitution. The petitioner had established a prima facie case with a probability of success, justifying the suspension of the DPO pending inter partes hearing, subject to conditions to prevent...

Court Disposition

Application allowed; conservatory order granted suspending DPO subject to conditions.

Orders

  • The Departure Prohibition Order issued on 6th September 2019 is suspended pending hearing and determination of the application inter partes.
  • The Applicant shall not leave Kenya pending inter partes hearing without giving seven days' written notice to the 1st Respondent, indicating destination, duration, and providing supporting documents.