[1996] KECA 105 (KLR)

[1996] KECA 105 (KLR)

The Court of Appeal held that the High Court erred in striking out the suit on the ground of res judicata. Two of the three prior suits relied upon did not support a finding of res judicata, and in the third suit, there was no finding as to whether the appellant was in possession of the land. Since the ascertainment...

Source-derived case information.

Citation
[1996] KECA 105 (KLR)
Parties
Appellant: John Karinga Kimanga; Respondent: Samuel Kamau Kamunge; Respondent: Joseph Njogu Kamunge
Court
Court of Appeal
Court Station
Court of Appeal at Nyeri
Jurisdiction
Kenya
Case Number
Civil Appeal 29 of 1996
Procedural Posture
Civil Appeal / Appeal From Judgment and Order Striking Out Suit at High Court on Preliminary Point of Law
Outcome
appeal allowed; case remitted for hearing on merits
Judges
AM Akiwumi, AB Shah
Legal Topics
Adverse Possession, Res Judicata, Rectification of Register
Source Language
en
Land and Property Civil Procedure Adverse Possession Res Judicata Rectification of Register

Source-derived case record

Summary, issues, holding and outcome

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Parties

John Karinga Kimanga

Appellant

Samuel Kamau Kamunge

Respondent

Joseph Njogu Kamunge

Respondent

Procedural Posture

Civil Appeal / Appeal From Judgment and Order Striking Out Suit at High Court on Preliminary Point of Law

  1. 1 Whether the suit was barred by res judicata due to previous litigation involving the same parties and subject matter.
  2. 2 Whether the issue of adverse possession could be determined without a full hearing of the facts.

Ratio Decidendi

The Court of Appeal held that the High Court erred in striking out the suit on the ground of res judicata. Two of the three prior suits relied upon did not support a finding of res judicata, and in the third suit, there was no finding as to whether the appellant was in possession of the land. Since the ascertainment of possession was essential to the issue of adverse possession, and no such finding had been made, the matter could not be determined as a preliminary point of law. The issue required a full hearing on the merits. The appeal was therefore allowed, and the case remitted to the High Court for hearing.

Court Disposition

appeal allowed; case remitted for hearing on merits

Orders

  • The appeal is allowed with costs here and in the court below.
  • The case is remitted to the superior court for hearing on merits.