Kibos Distillers Ltd & 4 others v Adega & 3 others (Civil Appeal 153 of 2019) [2020] KECA 875 (KLR)
The bottom line
#Kenya's Court of Appeal cancelled demolition orders against Kibos factories, ruled environmental disputes belong first to the environment tribunal, and penalised NEMA for disowning its own licences.
What this practically means
#Executive summary
#Questions the Court framed
#The issues the Court set itself to decide, in its own words.
- 1.Whether the learned judge erred in holding that the ELC had jurisdiction vis-a-vis the National Environment Tribunal and the National Environmental Complaints Committee
- 2.What probative value should attach to the additional evidence adduced before the Court
- 3.Whether the judge erred in failing to admit viva voce evidence
- 4.Whether the claim of constitutional violation was pleaded with specificity
- 5.Whether the judge erred in finding the three appellants responsible for polluting and degrading the environment contrary to Articles 42 and 43
- 6.Whether the judge erred in finding that the respondents' human rights had been violated
- 7.Whether the judge erred in finding the EIA Licences and their variation were illegally, unprocedurally and unconstitutionally acquired
- 8.Whether the judge erred in issuing the restorative and demolition orders
- 9.Whether the judge erred in failing to award compensation to the respondents
- 10.Whether the court erred in ordering the appellants to pay the costs of the petition
Key legal issues
#Jurisdiction of the ELC versus the NET and NECC
The ELC erred in assuming original jurisdiction; disputes on the validity of EIA Licences and alleged pollution fall within the original jurisdiction of the NET and NECC under EMCA.
The court held that multifaceted drafting cannot confer jurisdiction, that original jurisdiction is neither an ouster nor an all-inclusive clause, and that Section 129(3) of EMCA empowers the Tribunal to consider even the constitutional-flavoured prayers. The trial court's assumption of jurisdiction rendered otiose Section 130(5) of EMCA making ELC appellate decisions final.
Procedural validity of EIA Licence No. 0000259
The licence was lawfully issued under EMCA 1999 and Regulation 10(2) on the basis of a Project Report; no EIA study was required in 2004 and the judge erred in applying the EMCA 2015 amendments and the 2010 Constitution retrospectively.
Under EMCA 1999 as in force in 2004, only a Project Report was required, and Regulation 10(2) permitted NEMA to issue a licence where the project had no significant impact or disclosed sufficient mitigation. The presumption of regularity was not rebutted by conflicting statutory interpretation, and the 2010 Constitution's public participation values could not govern a 2005 licence.
Proof of pollution and the right to a clean environment
The trial court's finding of pollution was unsupported; pollution requires scientific, empirical and sampling evidence establishing point pollution and causal link.
The court re-evaluated the NECC, County Government and NEMA reports, finding no chemical analysis, no sampling technique, and no expert proof that vinasse was deleterious. Complaints raised over years were not proof of degradation. The NEMA Compliance Status Report of April 2019, admitted as additional evidence, showed 95-100% compliance and recommended lifting the closure order.
Viva voce evidence and fair hearing in constitutional petitions
Failure to take viva voce evidence did not vitiate the trial since no party applied for oral evidence or objected to the directions under Rule 20(1) of the Mutunga Rules, and no prejudice was demonstrated.
There is no automatic right to an oral hearing; the critical question is meaningful participation. Although in obiter the two hotly contested issues (licensing procedure and pollution) would have been better determined on oral evidence, the judge had a discretion that was not perversely exercised, and no credibility issues were raised.
Variation and transfer of EIA Licences
The trial judge erred in nullifying the variation and transfer; the conditions precedent in Section 64(1) EMCA 1999 were not shown to be fulfilled, and the discretion vested in NEMA could only be challenged on appeal to the Tribunal.
NEMA's letters of 9th November and 1st December 2010 approved the variations subject to audit conditions rather than cancelling the licences. No evidence showed substantial unforseeable threat or false information under Section 64(1). The judge usurped a discretion vested in NEMA and exercised original jurisdiction where only appellate jurisdiction existed.
Legal principles established
#- A litigant cannot confer jurisdiction on a court or oust that of a competent tribunal by the art and craft of drafting multifaceted pleadings; multifaceted claims are not a legally recognised mode of conferring jurisdiction.
- Original jurisdiction is not an ouster clause; where a clear procedure for redress is prescribed by the Constitution or an Act of Parliament, that procedure should be strictly followed.
- The absence of an environmental impact assessment study does not of itself create a presumption of environmental threat, harm or degradation.
- The procedural validity of a licence is determined by the law in force when it was issued; legislation is presumed prospective absent express retrospective intent.
- There is a presumption of regularity in the discharge of official duties, rebuttable only by cogent, clear and uncontroverted evidence.
- Neither urgency nor an alleged constitutional violation per se justifies dispensing with viva voce evidence; where a party applies for oral evidence the court should grant it unless it records reasons to the contrary.
Court orders
#- 1.Appeal allowed
- 2.Judgment, declaratory orders and decree of the Environment and Land Court in Kisumu ELC Petition No. 8 of 2018 delivered 31st July 2019 set aside in entirety, save as otherwise affirmed in the judgment
- 3.Findings in paragraphs 17 and 18 of the impugned judgment (that no EIA study was required for Licence No. 0000259) affirmed
- 4.Restorative, injunctive and demolition orders set aside
- 5.NEMA and/or NECC to continuously conduct inspections at the three appellants' factories to monitor compliance with environmental standards
- 6.The three appellants to annually (or as directed by a competent organ) conduct an environmental audit of their projects and submit a report to NEMA, NECC or other competent organ
- 7.The 1st, 2nd and 3rd respondents to jointly and severally bear the costs of the appeal and of the suit before the ELC
- 8.The 4th respondent (NEMA) to jointly bear the costs of the suit before the ELC and of the appeal with the 1st to 3rd respondents
The bench
#One judgment of the whole court — no separate or dissenting opinions.
Wrote the judgment
Wrote the principal judgment allowing the consolidated appeals, holding that the ELC lacked jurisdiction vis-a-vis the NET and NECC, that the EIA Licences were validly issued under EMCA 1999, and setting aside the trial judgment save for the affirmed findings, with costs against the respondents and NEMA.
In the final analysis, the upshot of the foregoing is that this appeal has merit and is hereby allowed.p. 29
Wrote the judgment
Concurred in a short separate judgment agreeing with the lead judgment of Makhandia JA in its entirety, including the allowance of the appeal and the costs orders.
I agree with the final determination allowing the consolidated appeal, as well as the orders on costs that he proposes.p. 30
- On appeal from
- Environment and Land Court of Kenya at Kisumu
- Petition No. 8 of 2018
- Jurisdiction invoked
- First appeal from the Environment and Land Court under Article 164 of the Constitution and the Court of Appeal Rules; judgment delivered under rule 32(3) of the Court of Appeal Rules following the death of Odek, JA
- Consolidated with
- Kisumu Civil Appeal No. 162 of 2019, Kisumu Civil Appeal No. 187 of 2019, Kisumu Civil Appeal No. 188 of 2019, Kisumu Civil Appeal No. 189 of 2019, Kisumu Civil Appeal No. 367 of 2019
Relief refused
#Finding of river pollution and environmental degradation against the appellants
No scientific, empirical or sampling evidence proved point pollution or a causal link to the appellants' activities
Demolition and closure orders against the appellants' structures
Disproportionate and overtaken by the demonstrated compliance in NEMA's April 2019 Compliance Status Report; no proof the structures per se caused pollution
Respondents' presumption that absence of an EIA study proves environmental harm
No legal principle or authority establishes such a presumption; harm is a question of fact
Costs
The 1st, 2nd and 3rd respondents shall jointly and severally bear the costs of this appeal and the costs before the ELC; the 4th respondent (NEMA) shall also jointly with the 1st, 2nd and 3rd respondents bear the costs of the suit before the ELC and in this appeal, its conduct in issuing and then disowning the EIA Licences being condemned by way of costs.
Quotable passages
#Verbatim from the judgment, each located to the page it appears on in the official PDF — so these can be cited and checked directly.
Save as otherwise affirmed in this judgment, I hereby set aside in entirety the judgment, declaratory orders and the decree of the Environment and Land Court delivered on 31st July 2019 in Kisumu ELC Petition No. 8 of 2018.
Accordingly, the 1st, 2nd and 3rd respondents shall jointly and severally bear the costs of this appeal and the costs before the ELC.
The concept of multifaceted claim is not a legally recognized mode for conferment of jurisdiction to any court or statutory body.
There is no presumption of threat or harm to the environment simply because no environmental impact assessment study has been done.
Pollution is primarily proved by empirical, technical and scientific evidence and not by lay man opinion testimony or depositions.
Settled principles of legislative construction presume that legislation is not intended as retroactive unless its language expressly makes it retroactive.
A public body cannot issue a licence and then turn around and disown the same. Such a conduct must be condemned by way of costs.
In the final analysis, the upshot of the foregoing is that this appeal has merit and is hereby allowed.
Issues in the judgment
#The judgment contains an internal tension: the court holds that the trial court had no jurisdiction and sets aside its judgment in entirety, yet still re-evaluates the merits, affirms findings in paragraphs 17 and 18 of the impugned judgment, and issues continuing supervisory orders.
The date of the ruling admitting additional evidence is inconsistently given as 10th October 2019 and 9th October 2019 within the same judgment.
Typographical error in the date of the petition ('25 th October 3028').
The judgment is delivered under rule 32(3) following the death of Odek, JA before delivery, so the judgment reflects the views of only two of the three coram judges.
Key timeline
#Practical implications
#Frequently asked questions
#Later judgments citing this (19)
#Judgments in the corpus that rely on this one. Where the Court said how it treated the authority, that is shown.
- Gichohi & another v Bajuun Properties Ltd & 2 others (Environment and Land Case E049 of 2023) [2026] KEELC 5146 (KLR)[2026] KEELC 5146 (KLR)31 Jul 2026
- Saiyuah v County Government of Narok & 3 others (Environment and Land Petition E008 of 2021) [2026] KEELC 5042 (KLR)[2026] KEELC 5042 (KLR)30 Jul 2026applied
- Baboon Project Kenya v Geothermal Development Company Ltd & another (Environment and Land Petition E003 of 2025) [2026] KEELC 4263 (KLR)[2026] KEELC 4263 (KLR)8 Jul 2026
- Ethics and Anti-corruption Commission v Kiptoo & 3 others (Environment and Land Case E009 of 2025) [2026] KEELC 4327 (KLR)[2026] KEELC 4327 (KLR)30 Jun 2026
- Mutungi v Mutungi & 5 others (Environment and Land Case E002 of 2026) (Environment and Land) [2026] KEELC 3748 (KLR)[2026] KEELC 3748 (KLR)18 Jun 2026followed
- Ethics & Anti-Corruption Commission v Kokita alias Halima Chelagat Kokota & 2 others (Environment and Land Case E008 of 2025) [2026] KEELC 2579 (KLR)[2026] KEELC 2579 (KLR)29 Apr 2026
- Rotich v Director General National Environment Management Authority & another (Environment and Planning Appeal E002 of 2025) [2026] KEELC 1672 (KLR)[2026] KEELC 1672 (KLR)19 Mar 2026
- Law Society of Kenya v Karura Golf Range Ltd & 7 others (Environment and Land Petition E003 of 2025) [2026] KEELC 1086 (KLR)[2026] KEELC 1086 (KLR)26 Feb 2026
- Nyariki & another (Suing as the Administrators of the Estate of Henry Nyariki Okara) v Sani & 4 others (Environment and Land Appeal E013 of 2024) [2026] KEELC 457 (KLR)[2026] KEELC 457 (KLR)4 Feb 2026
- Okumu v Agricultural Development Corporation & 9 others (Civil Appeal (Application) E112 of 2025) [2026] KECA 23 (KLR)[2026] KECA 23 (KLR)23 Jan 2026
- Kenya Anti-Corruption Commission & another v Mwamsae & 8 others (Environment and Land Case 8 of 2008) [2025] KEELC 8620 (KLR)[2025] KEELC 8620 (KLR)10 Dec 2025
- Sangahani & 2 others (For and on Behalf of Parklands Residents Association) v Nairobi City County Government & 5 others; 108 (Interested Party) (Petition E012 of 2025) [2025] KEELC 6985 (KLR)[2025] KEELC 6985 (KLR)14 Oct 2025
- Ekutan & 6 others v Jasto Mwiti alias “Sizzler” (Environment and Land Case E001 of 2025) [2025] KEELC 5819 (KLR)[2025] KEELC 5819 (KLR)30 Jul 2025applied
- Kenya Women Microfinance Bank Limited v County Government of Nakuru & another; Hunky Energy Limited (Interested Party) (Environment and Land Petition E007 of 2024) (Environment and Land) [2025] KEELC 4754 (KLR)[2025] KEELC 4754 (KLR)26 Jun 2025followed
- Gitonga v M’Itonga & 3 others (Environment and Land Appeal E017 of 2023) [2025] KEELC 4423 (KLR)[2025] KEELC 4423 (KLR)5 Jun 2025followed
- Watamu Association (Suing Through Its Elected Officials Claire Taylor, Bea Anderson & Damian Davies) v Wood & 3 others (Environment & Land Petition E003 of 2023) [2025] KEELC 3771 (KLR)[2025] KEELC 3771 (KLR)12 May 2025applied
- Washumbu (Directed Agricultural) Company Limited v Mbiriri & 4 others (Environment & Land Petition 1 of 2024) (Environment and Land) [2025] KEELC 2873 (KLR)[2025] KEELC 2873 (KLR)25 Mar 2025
- Ngoje & 7 others v National Irrigation Authority & another (Civil Appeal E090 & E097 of 2024 (Consolidated)) [2025] KEELC 771 (KLR)[2025] KEELC 771 (KLR)14 Feb 2025
- Kahia Transporters Limited & another v Chunky Limited & 8 others (Civil Appeal E011 of 2022) [2025] KECA 183 (KLR)[2025] KECA 183 (KLR)7 Feb 2025followed
Cite this brief
#Cite this brief
Caselaw, "Kibos Distillers Ltd & 4 others v Adega & 3 others (Civil Appeal 153 of 2019) [2020] KECA 875 (KLR)", Case Analysis (2020). Civil Appeal No. 153 of 2019 (consolidated with Kisumu Civil Appeals Nos. 162, 187, 188, 189 and 367 of 2019). Source: https://new.kenyalaw.org/akn/ke/judgment/keca/2020/875/eng@2020-01-31
Suggested citation format for research notes or client memos. Always verify the original judgment before relying on any point.