[1997] KECA 363 (KLR)

[1997] KECA 363 (KLR)

The Court of Appeal held that the High Court did not expressly grant leave to the appellants to apply for an order of prohibition as required under Order 53 of the Civil Procedure Rules. The consent order granted only the stay sought in prayer 3, conditional upon leave being granted, but did not itself grant leave....

Source-derived case information.

Citation
[1997] KECA 363 (KLR)
Parties
Appellant: Julius Ntogaiti M'Ethangatha; Appellant: Jason Kiiru Mbeeria; Appellant: Henry Ethaiba; Appellant: M'Iguathu M'Kiriti; Respondent: The District Land Adjudication Officer (Nyambene District); Respondent: M'Mutua M'Ikombo
Court
Court of Appeal
Court Station
Court of Appeal at Nairobi
Jurisdiction
Kenya
Case Number
? 161 of 1996
Procedural Posture
Civil Appeal / Judgment
Outcome
appeal dismissed
Legal Topics
Leave to Apply for Judicial Review, Order 53 Procedure, Prohibition Orders, Land Adjudication Disputes
Source Language
en
Civil Procedure Land and Property Leave to Apply for Judicial Review Order 53 Procedure Prohibition Orders Land Adjudication Disputes

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Summary, issues, holding and outcome

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Parties

Julius Ntogaiti M'Ethangatha

Appellant

Jason Kiiru Mbeeria

Appellant

Henry Ethaiba

Appellant

M'Iguathu M'Kiriti

Appellant

The District Land Adjudication Officer (Nyambene District)

Respondent

M'Mutua M'Ikombo

Respondent

Procedural Posture

Civil Appeal / Judgment

  1. 1 Whether the High Court granted leave to apply for an order of prohibition as required under Order 53 of the Civil Procedure Rules.
  2. 2 Whether the consent order granting prayer 3 amounted to a grant of leave to file the substantive motion for prohibition.
  3. 3 Whether the notice of motion for prohibition was properly before the court in the absence of an express order granting leave.

Ratio Decidendi

The Court of Appeal held that the High Court did not expressly grant leave to the appellants to apply for an order of prohibition as required under Order 53 of the Civil Procedure Rules. The consent order granted only the stay sought in prayer 3, conditional upon leave being granted, but did not itself grant leave. The requirement for leave is not a mere formality but a mandatory procedural step that must be satisfied in clear terms. In the absence of an express order granting leave, the notice of motion for prohibition was incompetent and the High Court was correct in dismissing it. The appeal was therefore dismissed with costs to the respondents.

Court Disposition

appeal dismissed

Orders

  • The appeal is dismissed with costs to the respondents.