[2021] KEELC 3189 (KLR)

[2021] KEELC 3189 (KLR)

The court found that the plaintiff had taken a step to prosecute the suit by obtaining a pretrial date before the applications for dismissal were filed. Therefore, the statutory requirement of one year of inactivity under Order 17 Rule 2 had not been met. The applications for dismissal were thus premature. The court...

Source-derived case information.

Citation
[2021] KEELC 3189 (KLR)
Parties
Plaintiff: Wakf Commissioners of Kenya; Defendant: Victor Waudi Okoth (as administrator of the Estate of Joseph Okoth Waudi-Deceased); Defendant: Casablanca Holdings Limited; Defendant: National Bank of Kenya; Defendant: Land Registrar, Mombasa
Court
Environment and Land Court
Court Station
Environment and Land Court at Mombasa
Jurisdiction
Kenya
Case Number
Environment & Land Case 283 of 2018
Procedural Posture
Miscellaneous Application / Ruling on Applications for Dismissal for Want of Prosecution
Outcome
applications for dismissal for want of prosecution dismissed
Legal Topics
Dismissal for Want of Prosecution, Pretrial Procedure, Service of Process, Land Ownership Disputes
Source Language
en
Civil Procedure Land and Property Dismissal for Want of Prosecution Pretrial Procedure Service of Process Land Ownership Disputes

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Parties

Wakf Commissioners of Kenya

Plaintiff

Victor Waudi Okoth (as administrator of the Estate of Joseph Okoth Waudi-Deceased)

Defendant

Casablanca Holdings Limited

Defendant

National Bank of Kenya

Defendant

Land Registrar, Mombasa

Defendant

Procedural Posture

Miscellaneous Application / Ruling on Applications for Dismissal for Want of Prosecution

  1. 1 Whether the suit should be dismissed for want of prosecution under Order 17 Rule 2 of the Civil Procedure Rules.
  2. 2 Whether the plaintiff had taken sufficient steps to prosecute the suit before the applications for dismissal were filed.
  3. 3 Whether the applicants were justified in filing the applications for dismissal at the material time.

Ratio Decidendi

The court found that the plaintiff had taken a step to prosecute the suit by obtaining a pretrial date before the applications for dismissal were filed. Therefore, the statutory requirement of one year of inactivity under Order 17 Rule 2 had not been met. The applications for dismissal were thus premature. The court also noted that while service of the pretrial date on all parties was not entirely clear, the applicants could not be faulted for believing there was inactivity. Nonetheless, the threshold for dismissal for want of prosecution was not satisfied, and the applications were dismissed without an order as to costs.

Court Disposition

applications for dismissal for want of prosecution dismissed

Orders

  • The applications dated 28 January 2020 and 8 May 2020 for dismissal of the suit for want of prosecution are dismissed.
  • No order as to costs.