[1999] KECA 119 (KLR)

[1999] KECA 119 (KLR)

The Court of Appeal held that the grounds advanced by the appellant for review—namely, the ownership of the vehicle and vicarious liability—were not proper grounds for review under Order 44 rule 1. The ownership of the vehicle was not denied in the pleadings and was not an issue at trial, thus could not be raised as...

Source-derived case information.

Citation
[1999] KECA 119 (KLR)
Parties
Appellant: Machakos Ranching Co. Ltd; Respondent: Waema Itumomuoka
Court
Court of Appeal
Court Station
Court of Appeal at Nairobi
Jurisdiction
Kenya
Case Number
Civil Appeal 266 of 1997
Procedural Posture
Civil Appeal / Appeal From Refusal to Review Judgment
Outcome
appeal dismissed
Legal Topics
Review of Judgment, Vicarious Liability, Ownership of Vehicle
Source Language
en
Civil Procedure Tort Law Review of Judgment Vicarious Liability Ownership of Vehicle

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Parties

Machakos Ranching Co. Ltd

Appellant

Waema Itumomuoka

Respondent

Procedural Posture

Civil Appeal / Appeal From Refusal to Review Judgment

  1. 1 Whether the High Court erred in refusing to review its judgment under section 80 of the Civil Procedure Act and Order 44 of the Civil Procedure Rules.
  2. 2 Whether there was a mistake or error on the face of the record regarding the ownership of the vehicle.
  3. 3 Whether vicarious liability was properly determined and could be a ground for review.

Ratio Decidendi

The Court of Appeal held that the grounds advanced by the appellant for review—namely, the ownership of the vehicle and vicarious liability—were not proper grounds for review under Order 44 rule 1. The ownership of the vehicle was not denied in the pleadings and was not an issue at trial, thus could not be raised as a new matter at the review stage. The issue of vicarious liability had been agreed upon by counsel and, even if disputed, would be a ground for appeal rather than review. The Court found no mistake or error apparent on the face of the record and no discovery of new evidence. Consequently, the High Court was correct in refusing to review its judgment, and the appeal lacked merit.

Court Disposition

appeal dismissed

Orders

  • The appeal is dismissed with costs.