[2020] KEHC 1728 (KLR)

[2020] KEHC 1728 (KLR)

The court found that the existence of a fee agreement between the advocate and the client was a material issue that was not considered by the taxing master during the initial taxation. The applicant did not bring the alleged agreement to the attention of the taxing master, and the issue did not feature in the...

Source-derived case information.

Citation
[2020] KEHC 1728 (KLR)
Parties
Respondent: W. K. Ngeno T/A Ngenoh Lessan & Co. Advocates; Applicant: Joseph Kipsigei Biegon & another (suing as personal representatives of the estate of the late Kipyegon Sang Alias Kibiegon Arap Sang)
Court
High Court
Court Station
High Court at Kericho
Jurisdiction
Kenya
Case Number
Miscellaneous Application 10 of 2018
Procedural Posture
Miscellaneous Application / Reference Against Taxation of Advocate Client Bill of Costs
Outcome
reference allowed; ruling and certificate of costs set aside; bill of costs to be taxed afresh before a different taxing master
Judges
AN Ongeri
Legal Topics
Advocate Client Costs, Fee Agreements, Taxation of Costs, Setting Aside Taxation
Source Language
en
Civil Procedure Commercial and Corporate Advocate Client Costs Fee Agreements Taxation of Costs Setting Aside Taxation

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Parties

W. K. Ngeno T/A Ngenoh Lessan & Co. Advocates

Respondent

Joseph Kipsigei Biegon & another (suing as personal representatives of the estate of the late Kipyegon Sang Alias Kibiegon Arap Sang)

Applicant

Procedural Posture

Miscellaneous Application / Reference Against Taxation of Advocate Client Bill of Costs

  1. 1 Whether there existed a binding fee agreement between the advocate and the client that would preclude taxation of costs.
  2. 2 Whether the taxing master erred by failing to consider the alleged fee agreement during taxation.
  3. 3 Whether the ruling on taxation and certificate of costs should be set aside and the bill of costs remitted for fresh taxation.

Ratio Decidendi

The court found that the existence of a fee agreement between the advocate and the client was a material issue that was not considered by the taxing master during the initial taxation. The applicant did not bring the alleged agreement to the attention of the taxing master, and the issue did not feature in the taxation proceedings. Given the provisions of Section 45 of the Advocates Act, which stipulate that costs are not subject to taxation where a fee agreement exists, it was necessary in the interests of justice for the taxing master to determine whether such an agreement existed. The failure to consider this issue rendered the taxation process defective. Consequently, the court set...

Court Disposition

reference allowed; ruling and certificate of costs set aside; bill of costs to be taxed afresh before a different taxing master

Orders

  • The ruling delivered on 20/6/2018 and the certificate of costs dated 6/7/18 are set aside.
  • The Bill of Costs dated 28/3/2018 shall be taxed afresh before any other taxing master other than the one who taxed it on 20/6/2018.