Bishop Paul Matumbi Muthuri v Trustees of the Methodist Church in Kenya & another [2020] eKLR Case Summary

Court
Employment and Labour Relations Court at Nairobi
Category
Civil
Judge(s)
Hon. Lady Justice Maureen Onyango
Judgment Date
October 09, 2020
Country
Kenya
Document Type
PDF
Number of Pages
3
Explore the case summary of Bishop Paul Matumbi Muthuri v Trustees of the Methodist Church in Kenya [2020] eKLR, highlighting key legal principles and findings from a significant decision affecting church governance.

Case Brief: Bishop Paul Matumbi Muthuri v Trustees of the Methodist Church in Kenya & another [2020] eKLR

1. Case Information:
- Name of the Case: Bishop Paul Matumbi Muthuri v. The Trustees of the Methodist Church in Kenya & Reverend Joseph Ntombura Mwaine
- Case Number: Cause No. 857 of 2019
- Court: Employment and Labour Relations Court, Nairobi
- Date Delivered: 9th October 2020
- Category of Law: Civil
- Judge(s): Hon. Lady Justice Maureen Onyango
- Country: Kenya

2. Questions Presented:
- Does the Employment and Labour Relations Court have jurisdiction to hear the dispute regarding the employment status of the Claimant, Bishop Paul Matumbi Muthuri, following his demotion and the subsequent actions of the Respondents?
- Are the Respondents in contempt of court for disobeying orders issued by the court regarding the Claimant's employment status and the installation of a new Bishop?

3. Facts of the Case:
- The Claimant, Bishop Paul Matumbi Muthuri, filed three applications against the Respondents, The Trustees of the Methodist Church in Kenya and Reverend Joseph Ntombura Mwaine, regarding his demotion from Bishop to an ordinary Church Minister, which he claimed was unlawful.
- The Claimant asserted that the Respondents failed to follow the Church's Constitution and Standing Orders in demoting him and that the dispute should have been resolved internally according to the Church's dispute resolution mechanisms.
- The Respondents contended that the Claimant's term as Bishop had expired on 31st December 2019, and thus he lacked standing to pursue the claims.

4. Procedural History:
- The Claimant filed an application for injunctions to restrain the Respondents from demoting him and from initiating disciplinary proceedings against him. The Respondents filed a preliminary objection asserting that the court lacked jurisdiction due to the absence of an employment relationship and the existence of arbitration clauses.
- The court heard the applications and the preliminary objection together, ultimately dismissing the preliminary objection while asserting its jurisdiction over the matter.

5. Analysis:
- Rules: The court's jurisdiction is derived from Article 162(2) and (3) of the Constitution of Kenya and Section 12 of the Employment and Labour Relations Court Act, which grants the court exclusive jurisdiction over employment and labour disputes.
- Case Law: The court referenced previous cases, including *Tononoka Steels Limited v Eastern and Southern Africa Trade and Development Bank* and *Andrew Inyolo Abwaza v Board of trustees of Pentecostal Assemblies of God-Kenya*, which emphasized that agreements attempting to oust the court's jurisdiction are generally prohibited.
- Application: The court found that the Claimant had established an employment relationship based on his appointment and salary vouchers, thereby confirming its jurisdiction. The court dismissed the Respondents' claims of lack of jurisdiction and locus standi, stating that the Claimant's employment status was a matter for determination.

6. Conclusion:
- The court ruled that it had jurisdiction over the case and dismissed the preliminary objection raised by the Respondents. The court found that the Claimant had not sufficiently proven contempt of court regarding the alleged disobedience of its orders and ultimately dismissed all applications filed by the Claimant.

7. Dissent:
- There were no dissenting opinions noted in the ruling.

8. Summary:
- The court's ruling confirmed its jurisdiction over employment disputes, rejecting the Respondents' claims of lack of jurisdiction and the Claimant's lack of standing. The applications for injunctions filed by the Claimant were dismissed, emphasizing the importance of following internal dispute resolution mechanisms within the church. The case underscores the balance between internal church governance and civil legal processes, highlighting the complexities involved in employment disputes within religious organizations.

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