[2004] KECA 62 (KLR)

[2004] KECA 62 (KLR)

The Court held that the appeal was incompetent because it was instituted in the name of Joe Louis Martin, who was already deceased at the time of filing. Rule 83(1) of the Court of Appeal Rules expressly prohibits the institution of an appeal in the name of a deceased person, requiring instead that such proceedings...

Source-derived case information.

Citation
[2004] KECA 62 (KLR)
Parties
Appellant: Joe Louis Martin; Respondent: Shyam Singh Bansal Ram
Court
Court of Appeal
Court Station
Court of Appeal at Kisumu
Jurisdiction
Kenya
Case Number
Civil Appeal 135 of 2000
Procedural Posture
Civil Appeal / Appeal Struck Out Preliminary Objection
Outcome
appeal_struck_out
Legal Topics
Appeal Incompetence, Party Deceased, Legal Representative Requirement
Source Language
en
Civil Procedure Appeal Incompetence Party Deceased Legal Representative Requirement

Source-derived case record

Summary, issues, holding and outcome

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Parties

Joe Louis Martin

Appellant

Shyam Singh Bansal Ram

Respondent

Procedural Posture

Civil Appeal / Appeal Struck Out Preliminary Objection

  1. 1 Whether an appeal can be instituted in the name of a deceased person.
  2. 2 Whether the appeal is competent in the absence of a legal representative for the deceased appellant.

Ratio Decidendi

The Court held that the appeal was incompetent because it was instituted in the name of Joe Louis Martin, who was already deceased at the time of filing. Rule 83(1) of the Court of Appeal Rules expressly prohibits the institution of an appeal in the name of a deceased person, requiring instead that such proceedings be brought by a legal representative. Both parties' counsel conceded this procedural defect. Consequently, the Court struck out the appeal as a nullity and awarded costs to the respondent.

Court Disposition

appeal_struck_out

Orders

  • The appeal is struck out as incompetent.
  • The respondent shall have the costs of the appeal.