[2019] KEHC 4298 (KLR)

[2019] KEHC 4298 (KLR)

The court held that section 333(2) of the Criminal Procedure Code requires that any period spent in custody prior to sentencing must be taken into account when computing the sentence. Since the appellant was in custody from the date of arrest until conviction and resentencing, the trial court erred by not ordering...

Source-derived case information.

Citation
[2019] KEHC 4298 (KLR)
Parties
Appellant: Matthew Mulinge Mutiso; Respondent: Republic
Court
High Court
Court Station
High Court at Machakos
Jurisdiction
Kenya
Case Number
Criminal Appeal 88 of 2018
Procedural Posture
Criminal Appeal / Ruling on Appeal Against Sentence Computation
Outcome
appeal allowed in part; sentence computation modified
Judges
BC Koech
Legal Topics
Robbery With Violence, Sentencing Principles, Remand Custody Credit, Resentencing, Penal Code Interpretation
Source Language
en
Criminal Law Robbery With Violence Sentencing Principles Remand Custody Credit Resentencing Penal Code Interpretation

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Parties

Matthew Mulinge Mutiso

Appellant

Republic

Respondent

Procedural Posture

Criminal Appeal / Ruling on Appeal Against Sentence Computation

  1. 1 Whether the trial court erred by failing to take into account the period spent in remand custody under section 333(2) of the Criminal Procedure Code when resentencing the appellant.
  2. 2 Whether the appellant is entitled to have his sentence run from the date of arrest.

Ratio Decidendi

The court held that section 333(2) of the Criminal Procedure Code requires that any period spent in custody prior to sentencing must be taken into account when computing the sentence. Since the appellant was in custody from the date of arrest until conviction and resentencing, the trial court erred by not ordering that the 20-year sentence run from the date of arrest. The High Court therefore substituted the trial court's order with one directing that the 20-year sentence commence from 24.11.2001, the date of arrest.

Court Disposition

appeal allowed in part; sentence computation modified

Orders

  • The 20 years imprisonment imposed on resentencing shall commence from the date of arrest, namely 24.11.2001.
  • The trial court's sentence is substituted accordingly.