[2025] KEHC 1454 (KLR)

[2025] KEHC 1454 (KLR)

The court held that Order 9 Rule 9 of the Civil Procedure Rules is couched in mandatory terms and must be complied with to effect a change of advocate after judgment. The applicant's new advocates had neither sought leave of court nor obtained consent from the outgoing advocates, and there was no evidence of service...

Source-derived case information.

Citation
[2025] KEHC 1454 (KLR)
Parties
Appellant: Dennis Isoe Moruri (Suing for and on Behalf of the Estate of Truphena Abisa Moruri); Respondent: Nyangena Hospital; Respondent: David Momanyi
Court
High Court
Court Station
High Court at Kisii
Jurisdiction
Kenya
Case Number
Civil Appeal 13 of 2020
Procedural Posture
Civil Appeal / Ruling on Preliminary Objection Regarding Change of Advocates Post Judgment
Outcome
Application not granted; applicant directed to serve application on previous advocates for determination before any further proceedings.
Judges
TA Odera
Legal Topics
Change of Advocate Post Judgment, Order 9 Rule 9 Compliance, Functus Officio, Inherent Jurisdiction, Service of Application
Source Language
en
Civil Procedure Change of Advocate Post Judgment Order 9 Rule 9 Compliance Functus Officio Inherent Jurisdiction Service of Application

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Parties

Dennis Isoe Moruri (Suing for and on Behalf of the Estate of Truphena Abisa Moruri)

Appellant

Nyangena Hospital

Respondent

David Momanyi

Respondent

Procedural Posture

Civil Appeal / Ruling on Preliminary Objection Regarding Change of Advocates Post Judgment

  1. 1 Whether the incoming advocates for the applicant could come on record without complying with Order 9 Rule 9 of the Civil Procedure Rules.
  2. 2 Whether the court had jurisdiction to grant orders sought after judgment and grant of stay, or was functus officio.
  3. 3 Whether failure to comply with Order 9 Rule 9 is a technicality curable under Article 159 of the Constitution.

Ratio Decidendi

The court held that Order 9 Rule 9 of the Civil Procedure Rules is couched in mandatory terms and must be complied with to effect a change of advocate after judgment. The applicant's new advocates had neither sought leave of court nor obtained consent from the outgoing advocates, and there was no evidence of service of the application on the previous advocates. Article 159 of the Constitution does not apply in this context as the advocate's right to fees is a substantive right protected by the procedural rule. The court further found that it lacked jurisdiction to grant the orders sought in the absence of compliance with Order 9 Rule 9 and proper service. Accordingly, the application...

Court Disposition

Application not granted; applicant directed to serve application on previous advocates for determination before any further proceedings.

Orders

  • The application be served upon M/s Nyamweya Mamboleo and Co. Advocates for determination first before any other issue can be dealt with.
  • Matter set for directions on 26.3.25.