Kodi Kodi Haven Ltd v Kamau (Environment and Land Appeal E015 of 2024) [2026] KEELC 2453 (KLR)
The bottom line
#A Nanyuki court confirmed a property buyer gets her Kshs. 481,000 refund because the company took over the seller's obligations and never followed its own contract notice rules.
What this practically means
#Executive summary
#Key legal issues
#Whether the appellant was bound by obligations relating to payments made to Kodi Kodi Limited
The appellant was the successor of Kodi Kodi Limited because clause 1(f) of the 9.6.2020 agreement recognized deposits paid through Kodi Kodi Limited's account, and its email of 21.1.2022 acknowledged the Kshs. 453,000 paid
Clause 1(f) of the 2020 agreement defined 'recognised deposit' as amounts paid through Kodi Kodi Limited's bank account, which would be inexplicable absent a relationship between the entities. Correspondence of 21.1.2022 showed the appellant acknowledging the exact sums paid to Kodi Kodi Limited. The privity-of-contract argument therefore failed; the appellant took over the responsibilities of Kodi Kodi Limited in respect of the suit plots.
Who breached the agreement of 9.6.2020
The appellant breached the agreement by failing to serve the 21-day completion notice required by clause 9.1 before invoking the non-completion procedure, and by failing to respond to the respondent's refund request
Clause 9.1 permitted invocation only after service of a 21-day written notice specifying the default. There was no evidence such notice was served. The respondent's email of 4.3.2022 requesting a refund went unanswered, and the appellant made no effort to tabulate accounts. The trial court's finding in favour of the respondent was therefore correct and the counterclaim of Kshs. 21,300 failed.
The duty of a first appellate court
The court, as the first appellate court, was entitled to reconsider and evaluate the evidence and draw its own conclusions subject to the absence of sight and sound advantage
Relying on Selle v Associated Motor Boat Company Ltd, the court restated that an appeal by way of retrial requires the appellate court to reconsider the evidence, evaluate it itself and draw its own conclusions, while making due allowance for not having seen or heard the witnesses. The court then undertook its own evaluation of the agreements, emails and accounts before dismissing the appeal.
Legal principles established
#- A first appellate court must reconsider and evaluate the evidence afresh while making due allowance for not having seen or heard the witnesses
- A party who recognizes funds paid to a predecessor entity in its own agreement is taken to be the successor of that entity
Court orders
#- 1.The appeal is dismissed with costs to the respondent
- On appeal from
- Trial court (magistrates' court, Nanyuki)
- Not stated
- Jurisdiction invoked
- First appellate jurisdiction over the trial court's judgment (appeal on facts and law)
Key timeline
#Practical implications
#Frequently asked questions
#Cite this brief
#Cite this brief
Caselaw, "Kodi Kodi Haven Ltd v Kamau (Environment and Land Appeal E015 of 2024) [2026] KEELC 2453 (KLR)", Case Analysis (2026). Not stated in the judgment as provided. Source: https://new.kenyalaw.org/akn/ke/judgment/keelc/2026/2453/eng@2026-04-22
Suggested citation format for research notes or client memos. Always verify the original judgment before relying on any point.