Mugeni v Ouma and Anor (Election Petition No. 15 of 2011)
Observed later treatment
No later-treatment classification is recorded for this judgment.
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Holding
Held that substituted service by publication of notice of presentation in a newspaper, containing all relevant details and to which the respondent responded by appearing in court, constituted effective service under court order. Held further that a supporters list for a Local Government Act election petition need not conform to the Parliamentary Elections format, provided it contains names, signatures, and voter registration numbers showing the signatories are registered voters in the constituency. Both preliminary objections dismissed.
Outcome
Preliminary objections dismissed — petition to proceed to substantive hearing
Facts
The Electoral Commission conducted elections for Chairperson of Busia District Council. The 1st respondent was declared winner. The petitioner, a registered voter in Busia Municipal Council, filed an election petition challenging the 1st respondent's academic qualifications, supported by a list of over 500 registered voters. The petitioner obtained a court order for substituted service and published notice of presentation in the Monitor newspaper on 17 May 2011, which included all relevant details but not a copy of the petition itself. Counsel for the 1st respondent appeared at the hearing after reading the newspaper notice. At commencement of the substantive hearing, respondents raised two preliminary objections: that the 1st respondent had not been effectively served because only the notice, not the petition, was advertised; and that the format of the supporters list did not conform to the form prescribed in the Parliamentary Elections regulations.
Issues
- Whether the petitioner effectively served the 1st respondent by substituted service through newspaper advertisement of notice of presentation only, without including a copy of the petition itself.
- Whether the list of supporters attached to the petition complied with the statutory requirements under the Local Government Act s.138(3)(b) notwithstanding its deviation from the format prescribed for parliamentary election petitions.
Orders
- Both grounds of preliminary objection dismissed.
- Costs of the preliminary objections awarded to the petitioner.
Rules and key headnotes
Legislation cited (6)
- Local Government Act s.138(3)(b)
- Parliamentary Elections Act s.60(2)(b)
- Parliamentary Elections (Election Petition) Rules r.6
- Civil Procedure Rules O.V r.2
- Civil Procedure Rules O.V r.18
- Interpretation Act s.43
Cases cited (7)
- Mbabali Jude v Electoral Commission (Election Petition No. 3 of 2006)
- Goyal v Goyal and Others [2009] EA 143
- Besweri Lubuye Kiwanuka v Electoral Commission and Daniel Kokoola (Election Petition Appeal No. 2 of 1999)
- Kistler v Tetner [1905] 1 KB 45
- Diamond v Croft 3 Ch D 512
- Craig v Kanssen [1943] KB 256
- Wanambwa Milton v Wanjusi Wasieba and Electoral Commission (Election Petition No. 1 of 2004)
Full judgment
The original judgment as reported. Read the original PDF before relying on any passage.