[2017] KEELC 2451 (KLR)

[2017] KEELC 2451 (KLR)

The court held that it cannot issue orders against non-parties, specifically the DCIO Naivasha and the Registrar of Persons, as they are not parties to the suit and have not been given an opportunity to be heard. Therefore, prayers seeking orders against them were dismissed. However, since there was no opposition...

Source-derived case information.

Citation
[2017] KEELC 2451 (KLR)
Parties
Plaintiff: Ruth Wanja Mwangi; Defendant: Samuel Mwaura Njuguna; Defendant: Naivasha Land Registrar; Defendant: Attorney General
Court
Environment and Land Court
Court Station
Environment and Land Court at Nakuru
Jurisdiction
Kenya
Case Number
Environment & Land Case 313 of 2014
Procedural Posture
Miscellaneous Application / Ruling on Interlocutory Application
Outcome
Application partially allowed.
Judges
DO Ohungo
Legal Topics
Discovery of Documents, Joinder of Parties, Land Title Disputes
Source Language
en
Civil Procedure Land and Property Discovery of Documents Joinder of Parties Land Title Disputes

Source-derived case record

Summary, issues, holding and outcome

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Parties

Ruth Wanja Mwangi

Plaintiff

Samuel Mwaura Njuguna

Defendant

Naivasha Land Registrar

Defendant

Attorney General

Defendant

Procedural Posture

Miscellaneous Application / Ruling on Interlocutory Application

  1. 1 Whether the court can compel non-parties (DCIO Naivasha and Registrar of Persons) to produce documents or disclose information in the suit.
  2. 2 Whether the 2nd defendant should be compelled to produce documents relating to the disputed land parcels.
  3. 3 Whether costs should be awarded to the applicant.

Ratio Decidendi

The court held that it cannot issue orders against non-parties, specifically the DCIO Naivasha and the Registrar of Persons, as they are not parties to the suit and have not been given an opportunity to be heard. Therefore, prayers seeking orders against them were dismissed. However, since there was no opposition from the 2nd defendant and section 22 of the Civil Procedure Act empowers the court to order discovery, the court granted the order compelling the 2nd defendant to produce the requested land documents. Costs of the application were awarded to the plaintiff.

Court Disposition

Application partially allowed.

Orders

  • Prayers 2 and 3 of the application, seeking orders against DCIO Naivasha and Registrar of Persons, are dismissed as they are not parties to the suit.
  • The 2nd defendant is ordered to produce documents and/or certified copies thereof of all documents deposited at the District Lands Registry as pertains to parcels of land known as MITI MINGI/MITI MINGI BLOCK 1/311 (MENENGAI) and MITI MINGI/MITI BLOCK 1/312 being sale and transfer documents.