https://new.kenyalaw.org/akn/ke/judgment/keca/2026/888

https://new.kenyalaw.org/akn/ke/judgment/keca/2026/888

The court held that despite the appeal having abated under Rule 102, it would overlook the inelegant framing of the motion and, in the interest of substantive justice, allow revival of the appeal and the motion for substitution as prayed, especially since the application was unopposed and supported by a death...

Source-derived case information.

Citation
[2026] KECA 888 (KLR)
Parties
Applicant: Marsha Birya Dena; 1st Respondent: Fred Karl Schumacher; 2nd Respondent: Hans Koschany; 3rd Respondent: DOPP Investments Limited
Court
Court of Appeal
Jurisdiction
Kenya
Case Number
Civil Appeal (Application) E076 of 2023
Procedural Posture
Civil Appeal (application) / Application for Substitution of Deceased Appellant and Leave to Revive Appeal
Outcome
Application allowed.
Judges
["F Tuiyott"]
Legal Topics
Substitution of Deceased Party, Revival of Abated Appeal, Limited Grant Ad Litem, Non Opposed Application, Interest of Substantive Justice
Source Language
en
Civil Procedure Appellate Practice Succession Substitution of Deceased Party Revival of Abated Appeal Limited Grant Ad Litem Non Opposed Application Interest of Substantive Justice

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Parties

Marsha Birya Dena

Applicant

Fred Karl Schumacher

1st Respondent

Hans Koschany

2nd Respondent

DOPP Investments Limited

3rd Respondent

Procedural Posture

Civil Appeal (application) / Application for Substitution of Deceased Appellant and Leave to Revive Appeal

  1. 1 Whether the deceased appellant could be substituted by the applicant.
  2. 2 Whether the appeal, having abated under Rule 102 of the Court of Appeal Rules 2022, should be revived.
  3. 3 Whether the court should overlook defective drafting in the motion in favour of substantive justice.

Ratio Decidendi

The court held that despite the appeal having abated under Rule 102, it would overlook the inelegant framing of the motion and, in the interest of substantive justice, allow revival of the appeal and the motion for substitution as prayed, especially since the application was unopposed and supported by a death certificate and a limited grant ad litem.

Court Disposition

Application allowed.

Orders

  • The appeal was revived.
  • The deceased appellant was to be substituted by Beatrice Kadzo Chengo.