[2024] KEELC 5215 (KLR)

[2024] KEELC 5215 (KLR)

The court found that the surveyor's report sought to be introduced by the defendant was already listed as document number 8 in the plaintiff's list of documents but had been expressly abandoned by the plaintiff during testimony. No notice to produce the document was issued by the defendant, and no sufficient reason...

Source-derived case information.

Citation
[2024] KEELC 5215 (KLR)
Parties
Plaintiff: Casmiel Mbori Ogendi alias Casmiel Mbori Ogendi; Defendant: Fredrick Onyango Odhiambo (Suing on Her Own Behalf and as the Legal Administrator of the Estate of Johnson Odhiambo Ogolo - Deceased)
Court
Environment and Land Court
Court Station
Environment and Land Court at Homa Bay
Jurisdiction
Kenya
Case Number
Enviromental and Land Originating Summons E002 of 2024
Procedural Posture
Environment and Land Originating Summons / Ruling on Application to File and Serve Additional Document
Outcome
application dismissed
Judges
GMA Ongondo
Legal Topics
Discovery of Documents, Late Filing of Evidence, Abandonment of Documents, Order 11 Civil Procedure Rules, Notice to Produce, Trial by Ambush
Source Language
en
Civil Procedure Land and Property Discovery of Documents Late Filing of Evidence Abandonment of Documents Order 11 Civil Procedure Rules Notice to Produce Trial by Ambush

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Parties

Casmiel Mbori Ogendi alias Casmiel Mbori Ogendi

Plaintiff

Fredrick Onyango Odhiambo (Suing on Her Own Behalf and as the Legal Administrator of the Estate of Johnson Odhiambo Ogolo - Deceased)

Defendant

Procedural Posture

Environment and Land Originating Summons / Ruling on Application to File and Serve Additional Document

  1. 1 Whether the defendant should be granted leave to file and serve an additional surveyor's report after the discovery stage.
  2. 2 Whether the application to introduce the document amounts to trial by ambush and contravenes Order 11 of the Civil Procedure Rules 2010.
  3. 3 Whether the plaintiff's abandonment of the document precludes its production by the defendant.

Ratio Decidendi

The court found that the surveyor's report sought to be introduced by the defendant was already listed as document number 8 in the plaintiff's list of documents but had been expressly abandoned by the plaintiff during testimony. No notice to produce the document was issued by the defendant, and no sufficient reason was advanced for the delay in filing and serving the document. The court held that the application was an afterthought, contrary to the requirements of Order 11 of the Civil Procedure Rules 2010, and amounted to trial by ambush. The court further held that Article 159(2)(d) of the Constitution could not be invoked to cure the procedural defect, as it is not intended to...

Court Disposition

application dismissed

Orders

  • The application to file and serve the additional surveyor's report is disallowed.
  • No order as to costs.