[2023] KEHC 22816 (KLR)

[2023] KEHC 22816 (KLR)

The court held that the applicant could not raise the issue of his age at the resentencing stage, as it was not raised during trial or appeal. However, applying the Supreme Court's guidance in the Muruatetu case, the court found that the mandatory life sentence previously imposed should be set aside. After...

Source-derived case information.

Citation
[2023] KEHC 22816 (KLR)
Parties
Applicant: PGM; Respondent: Republic
Court
High Court
Court Station
High Court at Nakuru
Jurisdiction
Kenya
Case Number
Miscellaneous Criminal Application 34 of 2020
Procedural Posture
Miscellaneous Criminal Application / Resentencing Application Following Conviction and Sentence
Outcome
Application partially allowed. Life sentence set aside and substituted with a custodial sentence of twenty years from October 28, 2011.
Judges
HK Chemitei
Legal Topics
Sentencing Principles, Juvenile Offenders, Life Imprisonment, Resentencing, Muruatetu Guidelines
Source Language
en
Criminal Law Sentencing Principles Juvenile Offenders Life Imprisonment Resentencing Muruatetu Guidelines

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Summary, issues, holding and outcome

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Parties

PGM

Applicant

Republic

Respondent

Procedural Posture

Miscellaneous Criminal Application / Resentencing Application Following Conviction and Sentence

  1. 1 Whether the applicant, convicted and sentenced to life imprisonment, is entitled to resentencing on the basis that he was a minor at the time of the offence.
  2. 2 Whether the life sentence should be set aside and substituted with a definite term in light of the Supreme Court decision in Muruatetu.

Ratio Decidendi

The court held that the applicant could not raise the issue of his age at the resentencing stage, as it was not raised during trial or appeal. However, applying the Supreme Court's guidance in the Muruatetu case, the court found that the mandatory life sentence previously imposed should be set aside. After considering the resentencing and prison reports, and despite negative aspects in the applicant's conduct while in custody, the court exercised its discretion to substitute the life sentence with a custodial sentence of twenty years, effective from the original sentencing date of October 28, 2011.

Court Disposition

Application partially allowed. Life sentence set aside and substituted with a custodial sentence of twenty years from October 28, 2011.

Orders

  • The life imprisonment sentence against the applicant is set aside.
  • The applicant is sentenced to twenty (20) years imprisonment from October 28, 2011.