[2019] KEELC 2802 (KLR)

[2019] KEELC 2802 (KLR)

The court held that Order 53 Rule 2 of the Civil Procedure Rules is couched in mandatory terms and requires that leave to apply for an order of certiorari must be sought within six months of the date of the impugned proceedings or award. In this case, the award was made on 14th April 2000 and adopted by the...

Source-derived case information.

Citation
[2019] KEELC 2802 (KLR)
Parties
Applicant: Milka Wambui Ndaba; Applicant: Solomon Mukonyo Ndaba; Respondent: Josphat Kinyanjui Mukonyo; Respondent: David Mbugua Mukonyo; Respondent: Joseph Ndaba Mukonyo; Respondent: Scheme Manager, Mwea Irrigation Scheme; Respondent: Principal Magistrate, Wang'uru Law Courts
Court
Environment and Land Court
Court Station
Environment and Land Court at Kerugoya
Jurisdiction
Kenya
Case Number
Environment & Land Case 1 of 2019
Procedural Posture
Judicial Review Application / Ruling on Leave to Apply for Judicial Review Orders
Outcome
application dismissed
Legal Topics
Judicial Review, Certiorari, Mandamus, Prohibition, Limitation Periods, Land Disputes
Source Language
en
Administrative Law Land and Property Judicial Review Certiorari Mandamus Prohibition Limitation Periods Land Disputes

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Parties

Milka Wambui Ndaba

Applicant

Solomon Mukonyo Ndaba

Applicant

Josphat Kinyanjui Mukonyo

Respondent

David Mbugua Mukonyo

Respondent

Joseph Ndaba Mukonyo

Respondent

Scheme Manager, Mwea Irrigation Scheme

Respondent

Principal Magistrate, Wang'uru Law Courts

Respondent

Procedural Posture

Judicial Review Application / Ruling on Leave to Apply for Judicial Review Orders

  1. 1 Whether the application for leave to apply for orders of certiorari, prohibition, and mandamus is time-barred under Order 53 Rule 2 of the Civil Procedure Rules.
  2. 2 Whether the court has jurisdiction to grant leave where the impugned award was made more than six months prior to the application.
  3. 3 Whether the ex-parte application is competent or an abuse of the court process.

Ratio Decidendi

The court held that Order 53 Rule 2 of the Civil Procedure Rules is couched in mandatory terms and requires that leave to apply for an order of certiorari must be sought within six months of the date of the impugned proceedings or award. In this case, the award was made on 14th April 2000 and adopted by the Magistrate's Court on 2nd May 2000, but the application for leave was filed on 29th January 2019, more than nineteen years later. The court found that it was bound by the statutory limitation period and had no jurisdiction to grant leave outside the six-month window. Consequently, the application was dismissed as incompetent and an abuse of the court process.

Court Disposition

application dismissed

Orders

  • The ex-parte application dated 29th January 2019 is dismissed for being incompetent and an abuse of the court process.
  • No order as to costs.