[2016] KEELC 741 (KLR)

[2016] KEELC 741 (KLR)

The court held that the application for dismissal for want of prosecution was premature because the last step in the proceedings was taken less than a year before the application, and substitution of the deceased defendant had not yet occurred. The court further found that the suit was not res judicata because the...

Source-derived case information.

Citation
[2016] KEELC 741 (KLR)
Parties
Plaintiff: John Mose Michira; Defendant: Barnaba Kipkosgei Surtan (deceased); Applicant: Edwin Kipkemboi Kosgei
Court
Environment and Land Court
Court Station
Environment and Land Court at Kitale
Jurisdiction
Kenya
Case Number
Land Case 173 of 2014
Procedural Posture
Land Case / Ruling on Interlocutory Application for Substitution, Dismissal for Want of Prosecution, and Eviction
Outcome
Application partly allowed.
Judges
EO Obaga
Legal Topics
Substitution of Parties, Dismissal for Want of Prosecution, Res Judicata, Eviction Orders
Source Language
en
Land and Property Civil Procedure Substitution of Parties Dismissal for Want of Prosecution Res Judicata Eviction Orders

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Summary, issues, holding and outcome

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Parties

John Mose Michira

Plaintiff

Barnaba Kipkosgei Surtan (deceased)

Defendant

Edwin Kipkemboi Kosgei

Applicant

Procedural Posture

Land Case / Ruling on Interlocutory Application for Substitution, Dismissal for Want of Prosecution, and Eviction

  1. 1 Whether the suit should be dismissed for want of prosecution.
  2. 2 Whether the suit is res judicata.
  3. 3 Whether eviction orders can be issued against the respondent at the interlocutory stage.

Ratio Decidendi

The court held that the application for dismissal for want of prosecution was premature because the last step in the proceedings was taken less than a year before the application, and substitution of the deceased defendant had not yet occurred. The court further found that the suit was not res judicata because the previous originating summons had been withdrawn and was not determined on its merits. The court also held that eviction orders could not be granted at the interlocutory stage in the absence of special circumstances and without a hearing of the main suit. The only meritorious prayer was for substitution of the applicant in place of the deceased defendant. Costs were ordered to...

Court Disposition

Application partly allowed.

Orders

  • The applicant Edwin Kipkemboi Kosgei is substituted in place of the deceased defendant Barnaba Kipkosgei Surtan.
  • All other prayers in the application are dismissed.