[2006] KEHC 595 (KLR)

[2006] KEHC 595 (KLR)

The court held that the application for substitution was made after the appeal had abated by operation of law, as more than one year had elapsed since the death of the appellant without any application for substitution. Under Order XXIII Rule 3(2) and Rule 10 of the Civil Procedure Rules, the appeal ceased to exist...

Source-derived case information.

Citation
[2006] KEHC 595 (KLR)
Parties
Appellant: Wekesa Sinino (deceased); Respondent: Marko Kusienya Sinino; Applicant: Belida Waliambila Wekesa
Court
High Court
Court Station
High Court at Kakamega
Jurisdiction
Kenya
Case Number
Civil Case 145 of 2003
Procedural Posture
Civil Appeal / Ruling on Application for Substitution After Abatement of Appeal
Outcome
Application for substitution struck out as incompetent; costs awarded to the respondent.
Legal Topics
Abatement of Suit, Substitution of Parties, Appeal Procedure, Adoption of Elders Award
Source Language
en
Civil Procedure Land and Property Abatement of Suit Substitution of Parties Appeal Procedure Adoption of Elders Award

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Parties

Wekesa Sinino (deceased)

Appellant

Marko Kusienya Sinino

Respondent

Belida Waliambila Wekesa

Applicant

Procedural Posture

Civil Appeal / Ruling on Application for Substitution After Abatement of Appeal

  1. 1 Whether the application for substitution of the deceased appellant was competent after the appeal had abated.
  2. 2 Whether the appeal had abated by operation of law under Order XXIII of the Civil Procedure Rules.
  3. 3 Whether the applicant should have revived the appeal before seeking substitution.

Ratio Decidendi

The court held that the application for substitution was made after the appeal had abated by operation of law, as more than one year had elapsed since the death of the appellant without any application for substitution. Under Order XXIII Rule 3(2) and Rule 10 of the Civil Procedure Rules, the appeal ceased to exist upon abatement, and there was no appeal in being at the time the application for substitution was made. The proper procedure would have been to first apply for revival of the abated appeal under Rule 8(2) before seeking substitution. As such, the application for substitution was incompetent and was struck out with costs to the respondent.

Court Disposition

Application for substitution struck out as incompetent; costs awarded to the respondent.

Orders

  • The application for substitution is struck out.
  • Costs of the application are awarded to the respondent.