[2021] KECA 833 (KLR)

[2021] KECA 833 (KLR)

The Court of Appeal held that the order sought to be stayed was a negative order, namely, the dismissal of the applicant's application for stay of execution by the High Court. Such an order does not require any positive act and is incapable of execution, and therefore cannot be stayed. The Court further noted that...

Source-derived case information.

Citation
[2021] KECA 833 (KLR)
Parties
Applicant: Michael Mwangi Guchura; Respondent: Martin Wambua Kitavi (Legal Representative of Kambua Kitavi, deceased)
Court
Court of Appeal
Court Station
Court of Appeal at Nyeri
Jurisdiction
Kenya
Case Number
Civil Application 167 of 2018
Procedural Posture
Stay Application / Application for Stay of Execution Pending Appeal
Outcome
application dismissed with costs to the respondent
Judges
FI Koome, AK Murgor
Legal Topics
Stay of Execution, Negative Orders, Appellate Jurisdiction, Enforcement of Judgments
Source Language
en
Civil Procedure Stay of Execution Negative Orders Appellate Jurisdiction Enforcement of Judgments

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Parties

Michael Mwangi Guchura

Applicant

Martin Wambua Kitavi (Legal Representative of Kambua Kitavi, deceased)

Respondent

Procedural Posture

Stay Application / Application for Stay of Execution Pending Appeal

  1. 1 Whether the Court of Appeal can grant a stay of execution against a negative order dismissing an application for stay of execution.
  2. 2 Whether the applicant is entitled to a stay of execution pending appeal in the absence of a notice of appeal against the trial court's decree.
  3. 3 Whether the existence of a pending appeal in the High Court precludes the Court of Appeal from granting a stay of execution.

Ratio Decidendi

The Court of Appeal held that the order sought to be stayed was a negative order, namely, the dismissal of the applicant's application for stay of execution by the High Court. Such an order does not require any positive act and is incapable of execution, and therefore cannot be stayed. The Court further noted that there was no notice of appeal against the decree of the trial court, and that an appeal against that decree was already pending before the High Court. Consequently, the Court of Appeal found no merit in the application for stay and dismissed it with costs to the respondent.

Court Disposition

application dismissed with costs to the respondent

Orders

  • The application for stay of execution is dismissed with costs to the respondent.