LEGAL SYSTEMS NOTES PT 2





 *DISCLAIMER*

The notes below are adapted from the Kenyatta University Teaching module and the students are adviced to take keen notice of the various legal and judicial reforms that might have been ocassioned since the module was adapted. the laws and statutes might also have changed or been repealed and the students are to be wary and consult the various statutes reffered to herein



Legal Systems:

There is no one uniform legal system the world over.  Law is based on society, the values, attitudes and customs will determine what legal systems they have in place.

Major legal systems in the world:

1.         ROMANO/GERMANIC SYSTEM

Codification of law i.e. statutes or written laws constitute the predominant formal source of law in this system.  This system is adopted in France, Germany Netherlands and most of continental Europe or civil law jurisdictions.  There is usually no emphasis on case law.

2.         COMMON LAW SYSTEM

This is primarily characterised by the predominant position occupied by case law or judicial precedence.

3.         SOCIALIST OR CAPITALIST SYSTEM

This system is uniquely characterised by welfarism and a lot of emphasis is placed on labour laws and social welfare laws.

4.         RELIGIOUS LEGAL SYSTEMS:

For example Islamic or Sharia Law which is in place in Islamic Republic of Iran, Nigeria and Saudi Arabia

5.         INQUISITORIAL VERSUS ADVERSARIAL (based on procedure)

In the inquisitorial systems the courts play a key role in inquiring the conduct of cases and are usually involved in for example summoning of witnesses, demanding particular evidence etc.  while in the adversarial system the presiding judge only acts as an umpire and is not involved in the presentation of the case.

In Kenya we have judicial and quasi judicial systems.  The quasi judicial systems play and adjudicative roles i.e. Commissions of inquiry and tribunals, administrators






SOURCES OF LAW

Kenyan case

1.         SPECIFIED ACTS OF THE UK PARLIAMENT

Under Part I of the Schedule to the Judicature Act Cap 8 Laws of Kenya, the following British Statutes are applicable in Kenya;
(i)                Admiralty Offences (Colonial) Act of 1849;
(ii)             The Evidence Act (Sections 7 and 11 thereof)
(iii)           Foreign Tribunals Evidence Act of 1856
(iv)            Evidence by Commission Act of 1859
(v)              British Law Ascertainment Act 1859
(vi)            Admiralty Offences (Colonial) Act of 1860
(vii)         Foreign Law Ascertainment Act of 1861
(viii)       Conveyancing (Scotland) Act of 1874 specifically S. 51 thereof
(ix)            Evidence by commission Act of 1885.

Under Part II of Schedule to the Judicature Act the President shall replace the Governor and a Magistrate holding a subordinate Court of the 1st Class shall replace a Magistrate of the Justice of Peace.

2.         STATUTES OF GENERAL APPLICATION AS AT 12TH AUGUST 1897

This is contained in Section 3 of the Interpretation and General Provisions Act Cap 2 of the Laws of Kenya.  The expression “Statutes of General Application” is not specifically defined in the Judicature Act, Cap 2 or in any other piece of legislation.  However, Kenya Courts have over the years accepted several UK Statutes as statutes of general application and applied them in determining certain cases.  Three basic criteria must be satisfied in order for a UK Act to be received and applied as a statute of general application:

(a)              It must have been enforced in the UK on the 12th day of August 1897;
(b)              It must have been applicable generally in the UK as at that date i.e. it must not have been a statute applicable only to a section of the UK or only to a section of the population;
(c)               The Statute must be suitable for the circumstances of Kenya and the inhabitants.

One Professor Allot in an article entitled “New Essays in African Law” has outlined a number of factors to be considered before UK Legislation can qualify as a statute of general application.  These are

(i)                The statute must be a government Act of the English legislature as distinguished from a local or private Act;
(ii)             The statute must have been in force in England at the specified reception date;
(iii)           The statute must be suitable for general application outside England;
(iv)            The Courts of the particular country concerned must rule on it;
(v)              When there is a local enactment which is inconsistent with the English statute then the local legislation prevails.

Some of the statutes of general application applied in Kenya include

1.                   Married Women’s Property Act of 1882  (see case of I v I) a 1971 case reported in EA law reports page 278;
2.                  Infants Relief Act of 1874.

3.         WRITTEN LAWS

These include

(a)              Indian Legislations which were imported into Kenya by the British Colonial Authorities;  however these have all been repealed with the exception of the ITPA;

(b)              Delegated Legislation these have the following advantages
(i)                Parliament does not have the time to legislate on all issues;
(ii)             They are speedy to enact and are therefore suitable for emergency intervention
(iii)           They are flexible or less rigid than Acts of Parliament and therefore they are easy to amend or appeal;
(iv)            Parliament will not usually have the requisite technical capacity. 

However there are disadvantages to delegated legislation

(a)              lack of adequate parliamentary control;
(b)              Lack of adequate Judicial control;
(c)               They are undemocratic as they are not made by democratically elected persons;
(d)              Too much delegated legislation contributes to uncertainty in the law;
(e)              There is the danger of sub-delegation.

With relation to delegated legislation, there are issues of ultra vires which have to be appreciated:  Substantive ultra vires i.e. the authority making the delegated legislation exceeds the powers granted by parliament; and Procedural ultra vires i.e where the authority making the delegated legislation contravenes any mandatory procedure set out in the parent statute.  Only ultra vires delegated legislation will be amenable for quashing by courts of law.

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