Galot v Manchester Outfitters Limited & 8 others (Civil Application E183 & E185 of 2024 (Consolidated)) [2026] KECA 441 (KLR) (6 March 2026) (Ruling)

Kenya Law

Automated Summary

Deceased Name

Mohan Galot

Key Facts

The case involves the substitution of Mohan Galot (deceased) in consolidated civil applications E183 and E185 of 2024. Mohan died on 8 June 2025, and the High Court granted letters of administration ad litem on 5 July 2025, later amended on 11 December 2025. The application for substitution was filed by Rajesh Galot and opposed by Avin Galot, who claimed legal authority to represent Mohan. The Court of Appeal allowed the substitution with costs in the appeal.

Issues

  • Whether the order from the superior court was authentic and properly issued.
  • Whether the applicant had the right to apply for substitution under rule 102(1) of the Court of Appeal Rules.

Date of Death

2025 June 08

Holdings

The court allowed the application for substitution of Mohan Galot with Avin Galot as the legal representative of the Estate of Mohan Galot, with costs in the appeal.

Remedies

The application for substitution of Mohan Galot with his legal representative, Avin Galot, is allowed with costs in the appeal.

Will Type

Intestacy

Probate Status

Letters of administration ad litem granted by the High Court on 5th July 2025 and amended on 11th December 2025.

Legal Principles

The court applied rule 102(1) of the Court of Appeal Rules, which permits any interested person to apply for the substitution of a deceased party with their legal representative in proceedings. The ruling clarified that such applications are not limited to the legal representative themselves and emphasized the procedural right to seek substitution when a party has died.

Precedent Name

Ngari vs. Muriithi (deceased) substituted by Wanjira Ngari & Another

Executor Name

Avin Galot

Cited Statute

Court of Appeal Rules

Executor Appointment

Appointed by court as administrator of Mohan Galot's estate

Judge Name

L.M. Ndoalo

Beneficiary Classes

Other

Passage Text

  • In the result, the application for substitution of Mohan Galot with the legal representative of the Estate of Mohan Galot being, Avin Galot is allowed with costs in the appeal.
  • A reading of rule 102(1) of the Rules of this Court indicates that an application for substitution can be made by any person who has an interest in the subject proceedings. The applicant in the consolidated application has a direct interest in the proceedings and there can be no legal basis to disallow the application because the Court was moved by a party other than the legal representative of the deceased.