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East African Court of Appeal

Crown v Getari wa Kachuqu (Revision Case No. 22 of 1927) [1927] EACA 20 (1 January 1927)

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Source document

01

Holding and result

The court held that the statutory definition of 'servant' under section 2 of the Employment of Natives Ordinance does not include clerks. Since the accused was employed as a clerk, he does not fall within the scope of persons regulated by the Ordinance for the purposes of the conviction. The conviction was therefore set aside and the fine ordered to be repaid.

Court disposition

conviction set aside

Orders

  • The conviction is set aside.
  • The fine ordered to be repaid to the accused.

02

Material facts

Parties

Crown

Respondent

Getari wa Kachuqu

Appellant

03

Procedural history

  1. Posture

    Criminal Revision / Judgment

04

Questions and positions

Legal issues

Whether a clerk falls within the definition of 'servant' under section 2 of the Employment of Natives Ordinance (Cap. 139).

Party arguments

Applicant
The accused was employed as a clerk and does not fall within the statutory definition of 'servant' under the Employment of Natives Ordinance (Cap. 139).
Respondent
The prosecution contended that the accused, being employed, should be considered a servant under the Ordinance.

05

Court’s reasoning

  1. 01

    Employment of Natives Ordinance (Cap. 139), section 2

    A clerk is not a servant as defined by section 2 of the Employment of Natives Ordinance (Cap. 139).

06

Ratio, limits and disposition

Ratio decidendi

The court held that the statutory definition of 'servant' under section 2 of the Employment of Natives Ordinance does not include clerks. Since the accused was employed as a clerk, he does not fall within the scope of persons regulated by the Ordinance for the purposes of the conviction. The conviction was therefore set aside and the fine ordered to be repaid.

Obiter and limits

  • A similar order was made by Sheridan, J., in Revision Case No. 43/1927.

Court disposition

conviction set aside

  • The conviction is set aside.
  • The fine ordered to be repaid to the accused.

Source and reliance status

East African Court of Appeal

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Judgment text

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Source document

East African Court of Appeal

Judgment

[1927] EACA 20

CRIMINAL REVISION.

Before SHERIDAN, J.

CROWN

$\boldsymbol{v}$ .

GETARI wa KACHUQU. Revision Case $22/1927$ .

Employment of Natives Ordinance (Cap. 139), section 2definition of servant.

$Held$ :—That a clerk is not a servant as defined in Section 2.

ORDER.-The evidence in this case shows the accused to have been employed as a clerk. A clerk does not come within the definition of servant in the Employment of Natives Ordinance (Cap. 139, section 2, Laws of Kenya).

The conviction is therefore set aside and the fine ordered to be repaid.

Note.-A similar Order was made by Sheridan, J., in Revision Case No. 43/1927.

Source wording is retained. Consult the source document for its original formatting and pagination.

Authorities

Authorities used by the court

Cases, legislation, regulations, and constitutional provisions identified in the available record.

Revision Case No. 43/1927

Case cited

Employment of Natives Ordinance (Cap. 139), section 2

Legislation

Legislation referenced in the available case record.

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