Electoral Commission v Watira Wilson (Election Petition Application No. 4 of 2022)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
The Court of Appeal struck out the respondent's election petition appeal. Following the dismissal of the respondent's earlier application for extension of time to file and validate the late-filed memorandum and record of appeal, there was no valid appeal on record. Because the appeal documents were lodged out of the statutory time, and the errors of the applicant's advocates in failing to take the essential step are visited on the client, the appeal could not stand. The application to strike out was accordingly allowed by default, with costs of the application and the appeal borne by the respondent.
Outcome
Application allowed; Election Petition Appeal No. 49 of 2021 struck out with costs against the respondent
Facts
The Electoral Commission applied to strike out Election Petition Appeal No. 49 of 2021, contending there was no valid appeal on record, that the respondent failed to take an essential step in the proceedings, and that no memorandum of appeal was filed within the prescribed time. The respondent, Watira Wilson, had earlier filed Miscellaneous Application No. 8 of 2021 seeking extension of time to file and serve the memorandum and record of appeal in Election Petition No. 012 of 2021 and validation of the late filing. That application was dismissed with costs, the court finding the applicant's advocates guilty of dilatory practice in failing to file within the statutory time. With no valid appeal remaining, the striking-out application was allowed by default.
Issues
- Whether Election Petition Appeal No. 49 of 2021 should be struck out for want of a valid appeal on record.
- Whether the respondent's failure to file the memorandum and record of appeal within the prescribed time warranted striking out the appeal.
Orders
- Election Petition Appeal No. 49 of 2021 be struck out.
- Costs of the application and the appeal to be borne by the respondent to this application.
Rules and key headnotes
Legislation cited (7)
- Judicature (Court of Appeal Rules) Directions rule 43(1)
- Judicature (Court of Appeal Rules) Directions rule 43(2)
- Judicature (Court of Appeal Rules) Directions rule 82
- Parliamentary Elections (Election Petitions) Rules rule 31
- Parliamentary Elections (Election Petitions) Rules rule 36
- Parliamentary Elections Act s.66
- Parliamentary Elections (Election Petitions) (Production of Records of Appeal) Directions SI 114-4
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.