Julius Orenge Advocate t/a Orenge J & Associates v Directline Assurance Company
The bottom line
#If your legal fees are taxed and you do not formally dispute the amount, the court can rule in your favor without a full trial.
What this practically means
#Executive summary
#Key legal issues
#Whether judgment on a Certificate of Taxation may be entered under Section 51(2) of the Advocates Act
Yes - where the certificate is unchallenged and the retainer is not disputed, the Court may enter judgment for the certified sum.
Section 51(2) provides that a taxing officer's certificate is final as to the amount of costs unless set aside or altered by the Court. The Respondent filed no reference, no application to set aside, and raised no dispute as to retainer or entitlement. The certificate therefore remained valid, binding and conclusive, warranting entry of judgment for the certified sum with interest.
Whether interest on the taxed fees is payable from 16th December 2025
Yes - Rule 7 of the Advocates (Remuneration) Order permits interest on fees due and payable; the claim for interest from 16th December 2025 was properly founded.
The Court invoked Rule 7 of the Advocates (Remuneration) Order, which permits an advocate to charge interest on fees due and payable subject to stipulated conditions. Satisfied that the claim for interest from 16th December 2025 was properly founded, the Court awarded interest at the applicable court's rate from that date until payment in full.
Legal principles established
#- Once a Bill of Costs has been taxed and a Certificate of Taxation issued, the certificate is final and conclusive as to the amount certified unless set aside or altered by the Court, and judgment may be entered for the certified sum where the retainer is not disputed.
Court orders
#- 1.Judgment entered in favour of the Advocate/Applicant against the Respondent in the sum of Kshs. 120,618/= being the amount certified in the Certificate of Taxation
- 2.The said sum shall attract interest at the applicable court's rate from 16th December 2025 until payment in full
- 3.A Decree shall issue upon payment of the requisite court fees
- 4.The Respondent shall pay to the Advocate/Applicant the costs of this application assessed at Kshs.15,000/=
- Jurisdiction invoked
- Section 51(2) of the Advocates Act, Section 3A of the Civil Procedure Act and the inherent jurisdiction of the court
Key timeline
#Practical implications
#Frequently asked questions
#Cite this brief
#Cite this brief
Caselaw, "Julius Orenge Advocate t/a Orenge J & Associates v Directline Assurance Company", Case Analysis (2026). . Source:
Suggested citation format for research notes or client memos. Always verify the original judgment before relying on any point.