Buchunju v Wanjula and 2 Others (Miscellaneous Application 23 of 2023)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that where a defendant dies and the legal representative seeks to participate in proceedings arising from a suit against the deceased, the legal representative must first obtain leave of court under Order 24 Rule 4 of the Civil Procedure Rules to be made a party before filing any substantive application. Failure to obtain such leave renders the legal representative without locus standi. Application dismissed.
Outcome
Application dismissed for lack of locus standi; applicant must first seek leave to be made a party to the underlying suit
Facts
Betty Perusi Olesi Buchunju, as administrator of the estate of the late Benjamin Buchunju, filed an application seeking to review and set aside a judgment and decree entered against the deceased in Civil Suit No. 53 of 2010. The deceased had been a defendant in that suit. The applicant brought the application without first obtaining leave of court to be made a party to Civil Suit No. 53 of 2010 as legal representative of the deceased defendant. The first respondent raised a preliminary objection that the applicant lacked locus standi to bring the application. The applicant's counsel did not file any submissions in reply to the preliminary objection.
Issues
- Whether the applicant had locus standi to bring the application without first obtaining leave of court to be made a party to the underlying suit as legal representative of the deceased defendant.
Orders
- Preliminary objection sustained.
- Application dismissed.
- Costs to be paid by counsel in personal conduct of the application for lack of care in representing the applicant.
Rules and key headnotes
Legislation cited (9)
- Judicature Act Cap.13 s.33
- Civil Procedure Act Cap.71 s.82
- Civil Procedure Act Cap.71 s.98
- Civil Procedure Rules O.9 r.12
- Civil Procedure Rules O.9 r.29
- Civil Procedure Rules O.52 r.1
- Civil Procedure Rules O.52 r.2
- Civil Procedure Rules O.52 r.3
- Civil Procedure Rules O.24 r.4
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.