Kenya Judgment

Court of Appeal · Court of Appeal at Kisumu

[2003] KECA 206 (KLR)

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Source document

01

Holding and result

The Court of Appeal held that the initial portion of the prosecution was conducted by a police constable, who was not authorized to act as a public prosecutor under section 85(2) of the Criminal Procedure Code. This defect rendered the entire trial a nullity, as any material defect in the conduct of a criminal trial invalidates the whole proceeding. The subsequent prosecution by an Inspector did not cure the defect. The Court further determined that a retrial was appropriate since there was no evidence that witnesses could not be traced and the appellants did not strongly oppose a retrial. The convictions were quashed, sentences set aside, and a retrial ordered.

Court disposition

conviction quashed, sentence set aside, retrial ordered

Orders

  • The convictions of the appellants are quashed.
  • The sentences of death imposed on the appellants are set aside.
  • A retrial of the appellants is ordered.
  • The appellants are to be remanded in custody pending retrial.

02

Material facts

Parties

Thomas Ogamba Nyakundi

Appellant Counsel: Mr Onsongo

Jairus Mose Nyakundi

Appellant Counsel: Mr Onsongo

Republic

Respondent

Amounts and remedies

  • Value of Stolen Property: KES 11,807

03

Procedural history

  1. Posture

    Criminal Appeal / Second Appeal From Conviction and Sentence After Trial and First Appeal

04

Questions and positions

Legal issues

Party arguments

Applicant
The appellants, through their counsel, argued that the entire trial was a nullity because the prosecution was conducted in part by a police constable, who was not authorized under section 85(2) of the Criminal Procedure Code to act as a public prosecutor. They contended that this defect vitiated the whole trial and conviction.
Respondent
The respondent did not strenuously oppose a retrial and did not provide evidence that tracing prosecution witnesses for a retrial would be difficult. The respondent relied on the validity of the proceedings conducted by the Inspector but did not contest the legal defect raised.

05

Court’s reasoning

  1. 01

    Criminal Procedure Code (cap 75) section 85(2)

    A prosecution conducted by a police officer below the rank of assistant inspector is a nullity under section 85(2) of the Criminal Procedure Code.

  2. 02

    Elirema & another v Republic [2003] KLR 537

    If any part of a criminal trial is materially defective, the entire trial is invalidated.

  3. 03

    General principles of criminal procedure

    A retrial may be ordered where the interests of justice require it and there is no evidence that witnesses cannot be traced or that a retrial would be unfair.

06

Ratio, limits and disposition

Ratio decidendi

The Court of Appeal held that the initial portion of the prosecution was conducted by a police constable, who was not authorized to act as a public prosecutor under section 85(2) of the Criminal Procedure Code. This defect rendered the entire trial a nullity, as any material defect in the conduct of a criminal trial invalidates the whole proceeding. The subsequent prosecution by an Inspector did not cure the defect. The Court further determined that a retrial was appropriate since there was no evidence that witnesses could not be traced and the appellants did not strongly oppose a retrial. The convictions were quashed, sentences set aside, and a retrial ordered.

Obiter and limits

  • The Court noted that the issue of prosecution by unqualified persons had been addressed in previous decisions and reaffirmed the principle that such trials are nullities.
  • The Court observed that the ends of justice would be served by ordering a retrial, given the circumstances and absence of opposition from the appellants' counsel.

Court disposition

conviction quashed, sentence set aside, retrial ordered

  • The convictions of the appellants are quashed.
  • The sentences of death imposed on the appellants are set aside.
  • A retrial of the appellants is ordered.
  • The appellants are to be remanded in custody pending retrial.

Source and reliance status

Court of Appeal

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Judgment text

The complete available source text.

Source document

Court of Appeal

Judgment

[2003] KECA 206 (KLR)

REPUBLIC OF KENYA

IN THE COURT OF APPEAL OF KENYA

AT KISUMU

CRIMINAL APPEAL NO 217 OF 2003

Between

NYAKUNDI & ANOTHER

V

REPUBLIC

Criminal Practice and Procedure – conduct of prosecution - prosecution by unqualified persons – prosecution conducted by police officer of the rank of Police Constable - prosecution later conducted by Police Inspector - whether proceedings proper.

Criminal Practice and Procedure – retrial – circumstances in which a retrial can be ordered - prosecution nullified for being conducted by an unauthorised person - no evidence that it would be difficult to trace witnesses - whether proper to order retrial.

The appellants were tried, convicted and sentenced to death on charges of robbery with violence. The prosecution had been conducted by a police officer of the rank of police constable contrary to section 85(2) of the Criminal Procedure Code. After a break the prosecution was conducted by an officer of the rank of Inspector.

Held:

1. Police Constable Nakori was clearly not entitled to act as a Public Prosecutor. It must follow therefore, that portion of the prosecution must be rendered a nullity, however, the part of the trial conducted by Inspector Okoth was valid. As there was only one trial and if any part of it was materially defective, the whole trial must be invalidated.

2. Taking into account the circumstances of the case, the ends of justice would be served if we ordered a retrial as the court has not been told that it would be difficult to trace the prosecution witnesses neither was a retrial strenuously opposed. Conviction quashed, sentence set aside, retrial ordered.

Cases

Elirema & another v Republic [2003] KLR 537

Statutes

Criminal Procedure Code (cap 75) section 85(2) Advocates

Mr Onsongo for the Appellants.

November 28, 2003, the following Judgment of the Court was delivered. This is an appeal from the judgment of the superior court (Wambilyangah J) delivered on 25th September 2002. In the Memorandum of Appeal (which is stated to be petition of appeal) five grounds of appeal are set out but when the appeal came up for hearing on 25th November 2003, Mr Onsongo, counsel for the appellants, was of the view that the appeal could be decided upon one ground only which was to the effect that there was a mistrial before the Senior Resident Magistrate’s Court. The fourth ground of appeal stated:-

“4. The entire trial was a nullity as the court prosecutor was not a person entitled to prosecute on the basis of the provisions of section 85 (2) of the Criminal Procedure Code.”

The appellants herein, Thomas Ogamba Nyakundi and Jairus Mose Nyakundi were jointly charged with robbery with violence contrary to section 296(2) of the Penal Code. The particulars of the offence were that on the 24th day of September 2001 at about 8. 00 pm at Nyaigesa village Miruka sub location in Nyamira district of the Nyanza province jointly with others not before court while armed with pistols, pangas and rungus and other crude weapons they robbed Douglas Mongare Nyaundi of cash Kshs 5,157/= and a radio cassette make National Panasonic valued at Kshs 6,650/= all valued at Kshs 11,807/= and at or immediately before or immediately after the time of such robbery, used actual violence against him in order to obtain or retain the property so stolen. The trial commenced before the Senior Resident Magistrate, Mr K W Kiarie on 25th October, 2001. The prosecutor was PC Makori. It is recorded that three prosecution witnesses testified and the trial was then adjourned to 12th November 2001. There was, however, no hearing on 12th November 2001 as the trial was adjourned once again to 23rd November 2001, when Inspector Okoth (and not P C Makori) appeared for prosecution. Two witnesses were called by the prosecution and then the appellants defended themselves on oath. They called two defence witnesses who also testified. Judgment was then reserved to 7th December, 2001, when the appellants were convicted as charged and each of them sentenced to death as mandatorily provided by the law. Their first appeal to the Superior Court was dismissed as already stated on 25th September, 2002. They now come before this Court by way of second appeal.

In this appeal a point of law has been raised to the effect that the entire trial was a nullity as the court prosecutor was not a person entitled to prosecute on the basis of the provisions of section 85(2) of the Criminal Procedure Code which provides:

“The Attorney General by writing under his hand, may appoint any advocate of the High Court or person employed in the public service, not being a police officer below the rank of assistant inspector of police to be a public prosecutor for the purposes of any case.”

(underlying provided) According to the narrative we have given above as relates to the trial before the learned senior resident magistrate, the first portion of the prosecution was conducted by Police Constable Makori when three prosecution witnesses testified. The second portion of the prosecution was conducted by Inspector Okoth.

In view of the foregoing, Police Constable Makori did not, in law, have authority to prosecute as a public prosecutor as he was below the rank of Inspector of police. He was clearly not entitled to act as a public prosecutor. It must follow, therefore, that the portion of the prosecution must be rendered a nullity, however, the part of the trial conducted by Inspector Okoth was valid. As there was only one trial and if any part of it was materially defective, the whole trial must, in our view, be invalidated. This Court has dealt with this issue of prosecution by unqualified persons in its decision in Roy Richard Elirema and Vincent Joseph Kessy v Rep – Criminal Appeal No 67 of 2002 (unreported), which we would adopt in this appeal. We therefore declare that the trial of the appellants in which a police constable purported to act as public prosecutor is a nullity with the result that their conviction must be and is hereby quashed and the sentence of death passed on each appellant set aside.

What then must follow? Should we order a retrial or should we release the appellants? The alleged offence took place in September, 2001 in Nyamira district of Nyanza province. We have not been told that it would be difficult to trace the four main prosecution witnesses for a re-trial and since counsel for the appellants did not strenuously oppose a retrial, we are of the view that taking into account the circumstances of this case, the ends of justice would be served if we order a retrial. Accordingly, we order that there shall be a re-trial of the appellants. Meanwhile, the appellants who are to be re-tried on a non bailable offence are to be remanded in custody pending the retrial.

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Authorities

Authorities used by the court

Cases, legislation, regulations, and constitutional provisions identified in the available record.

Elirema & another v Republic [2003] KLR 537

Case cited

Roy Richard Elirema and Vincent Joseph Kessy v Republic Criminal Appeal No 67 of 2002 (unreported)

Case cited

Criminal Procedure Code (cap 75) section 85(2)

Legislation

Legislation referenced in the available case record.

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