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Awange & another v Oyolla & another (Civil Appeal E454 of 2024) [2026] KECA 377 (KLR) (27 February 2026) (Judgment)

[2026] KECA 377 (KLR) Court of Appeal
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Court
Court of Appeal
Case number
377
Citation
[2026] KECA 377 (KLR)
Decided
27 February 2026
AI Summary Beta Machine-generated — may contain errors. Not legal advice.
TypeCivil AppealPostureAppeal from the judgment and decree of the Environment and Land CourtCoramInnes, Madan, Oguttu Mboya, PO KIAGE, WK KORIR
Holding

The appeal is allowed; the declarations of trust and all rectification orders are set aside; ownership of L.R. No. 209/14990/16 remains vested in the appellant; the matter is remitted to the ELC before a Judge other than Oguttu Mboya, J. solely for the purpose of determining whether the 1st respondent strictly proved that he advanced identiable monetary sums to the appellant toward acquisition of the suit property and, if so, the net amount recoverable in restitution, if any.

Facts

The suit property is a developed parcel of land whereon stands an ongoing development of a twelve-storey apartment block. The parties in the appeal are the registered owner of the suit property, her corporate vehicle, and a third-party investor that undertook construction on the suit property.

Issues

  1. Whether the 1st respondent established a constructive or resulting trust.
  2. Whether the ELC erred in granting reliefs not pleaded or supported by evidence.
  3. Whether the procedural aws raised by the Appellants vitiate the decision.
  4. Whether the 2nd respondent is a bona de purchaser for value.
  5. Whether the judgment is capable of execution.
  6. Whether the appeal is merited.
  7. Who should bear the costs of the appeal?

Reasoning

The Court found that the 1st respondent did not establish a constructive or resulting trust, and the ELC erred in granting reliefs not pleaded or supported by evidence. The procedural flaws raised by the Appellants were not sufficient to vitiate the decision. The 2nd respondent is not a bona de purchaser for value, and the judgment is not capable of execution.

Outcome

The appeal is allowed.

Orders

  • The declarations of trust and all rectification orders are set aside.
  • Ownership of L.R. No. 209/14990/16 remains vested in the appellant.
  • The matter is remitted to the ELC before a Judge other than Oguttu Mboya, J. solely for the purpose of determining whether the 1st respondent strictly proved that he advanced identiable monetary sums to the appellant toward acquisition of the suit property and, if so, the net amount recoverable in restitution, if any.
Experimental AI summary generated by a language model, not a lawyer. It may contain errors or omissions and must not be relied on for legal decisions — the full judgment below is the authoritative source.
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