Chaudhri & Associates v Registered Trustees of Sheikh Zayed Bin Sultan Al-Nahyan (Miscellaneous Civil Application E204 of 2022) [2026] KEELC 4833 (KLR)

Rule 11 of the Advocates (Remuneration) Order requires an aggrieved party to file a notice of objection within 14 days specifying the items objected to. The notice is the equivalent of a memorandum of appeal and cannot be omnibus. Perusal of the court record showed no notice of objection was ever filed, not even an incompetent one, so the Reference was incompetent and the entire application failed on that ground alone.

The court acknowledged the Client did oppose the Bill and the Taxing Master erred in finding it unchallenged. However, the Taxing Master set out reasons for taxing each item, and the Client failed to show prejudice. VAT is a statutory charge under the VAT Act; the 50% increment is prescribed by Schedule VI for Advocate-Client bills; and costs of taxation follow the event under Section 27 of the Civil Procedure Act.

Under Section 51(2) of the Advocates Act, an unaltered certificate of costs is final as to quantum and judgment may be entered on it. Rule 7 of the Remuneration Order was inapplicable because the Advocate had included a charge for interest in the Bill, and per the Otieno Ragot authority, inclusion of interest in the bill negates Rule 7 and leaves interest to the court's discretion under Section 26 of the Civil Procedure Act. The court exercised that discretion, awarding 14% per annum from one month after the certificate was issued.