Defining Prima Facie Cases: Mrao and Injunction Law
An injunction can stop a sale, freeze the use of property, restrain a business step or preserve a disputed right before a full trial has taken place. Because that power can have serious consequences, a court does not grant temporary relief merely because a dispute exists. Mrao Ltd v First American Bank of Kenya explains the first and most important screening question: has the applicant shown an apparently existing right and an apparent infringement that genuinely requires an answer?
The phrase used by lawyers
is a prima facie case. It can sound abstract, but Mrao makes it practical. The
applicant must do more than identify an argument worth discussing. The evidence
placed before the court must connect a legal right to conduct that appears to
violate or threaten it, while leaving the final merits for trial.
The
banking dispute behind the famous test
Mrao Ltd had borrowed
substantial sums from First American Bank of Kenya and granted securities over
property and company assets. After default, the bank appointed receivers and
moved to enforce its security. Mrao sought interlocutory injunctions to restrain
enforcement and challenged aspects of the charge, debenture and receivership.
The High Court refused
temporary relief. On appeal, the Court of Appeal in Mrao Ltd v First American
Bank of Kenya Ltd & 2 others [2003] KECA 175 (KLR) upheld that refusal.
The case became famous not
because of the amount borrowed, but because the Court explained what the first
limb of the Giella v Cassman Brown test actually requires. A prima facie case
is more than a genuine or arguable dispute. The material must show an apparent
right and an apparent infringement that calls for explanation or rebuttal.
A
prima facie case is evidence, not a conclusion
An injunction application is
usually supported by affidavit evidence. The court therefore asks what the
documents show at first sight without conducting a full trial. A claimant who
simply states that a contract is invalid, that a bank acted fraudulently or
that property is in danger has not necessarily established the threshold.
The right should be
identified first. It might arise from ownership, contract, statute,
intellectual property, employment, membership or another legally recognised
interest. The next question is what specific act threatens or infringes that
right. The affidavit should then attach the material that makes the
infringement apparent.
This is why an application
built around documents is generally stronger than one built around adjectives.
A statutory notice, agreement, title, valuation, correspondence, account
statement or official decision can connect the legal theory to a concrete event.
The court is not being asked to decide finally that the applicant will win. It
is being asked to see enough lawful substance to justify preserving the
position while the suit proceeds.
Mrao
does not replace the rest of the injunction test
The Court of Appeal's later
decision in Nguruman Ltd v Jan Bonde Nielsen & 2 others [2014] KECA 606
(KLR) clarified the sequence. The three familiar Giella requirements are
separate hurdles. First, the applicant must establish a prima facie case. Second,
the applicant must show irreparable injury that damages would not adequately
repair. Third, where appropriate doubt remains, the balance of convenience is
considered.
A strong prima facie case
therefore does not automatically produce an injunction. The applicant still has
to explain the harm that will occur if the court does nothing before trial.
Conversely, where no prima facie case is shown, a court should not jump to
irreparable harm or convenience as a way of rescuing a weak claim.
That sequential method
remains routinely applied in recent Kenyan rulings, including commercial and
land disputes decided in 2025. Mrao is therefore not an old banking formula
that has faded from practice. Its definition continues to structure everyday applications
for interim protection.
The
current Civil Procedure Rules make the procedure concrete
Order 40 of the Civil
Procedure Rules governs temporary injunctions and interlocutory orders. Rule 1
allows temporary protection where property in dispute is in danger of being
wasted, damaged, alienated or wrongfully sold in execution, or where a defendant
threatens to dispose of property in circumstances that could obstruct a future
decree. Rule 2 permits an injunction to restrain breach of contract or other
injury.
The Rules also impose
procedural discipline. An ex parte injunction is exceptional and time-limited,
service must follow promptly, and applications are to be heard expeditiously.
An interlocutory injunction that remains in place while a suit is not determined
for twelve months will ordinarily lapse unless the court orders otherwise for
sufficient reason.
Those provisions reinforce
Mrao's policy logic. Interim relief is meant to preserve justice pending trial,
not to become a substitute for trial.
What
Mrao means in a modern bank-sale dispute
Bank enforcement remains one
of the settings in which Mrao is frequently cited. The legal framework is now
shaped by the Land Act. Section 90 requires a chargee to issue a written
default notice containing specified information and giving the chargor the
statutory opportunity to remedy default. Section 96 requires a further notice
before the power of sale is exercised, while section 97 imposes a duty of care
and requires a forced-sale valuation.
A borrower seeking an
injunction should therefore identify the precise alleged defect. Was the
section 90 notice never served? Was the statutory period shortened? Was the
section 96 notice missing? Was the valuation omitted or materially defective?
Was the proposed sale inconsistent with the charge?
A bare dispute about the
amount owed may not, without more, establish an apparent violation of a legal
right. Recent 2025 banking decisions continue to use Mrao precisely in this
way: the court asks whether the bank's own enforcement record reveals a statutory
or contractual defect serious enough to satisfy the prima facie threshold.
Avoiding
the mini-trial problem
There is an important limit
on the test. A judge deciding an interlocutory application should not make
final findings on contested fraud, ownership, breach or credibility. Doing so
can prejudge the trial before witnesses have been examined and the complete
record has been tested.
Nguruman stresses that the
court should identify a clear right threatened with material invasion without
closely examining the merits as though deciding the suit. Mrao is demanding
because the applicant must show more than an arguable issue, but it remains
provisional.
For advocates, the drafting
skill is to show enough without asking the court to decide everything. The
affidavit should demonstrate the right and the immediate threat, while the
submissions explain why the material reaches the threshold. Arguments reserved
for final liability should remain for trial.
A
practical checklist without turning the case into a checklist
The best injunction
application tells a short evidential story. It identifies the right, attaches
the document that proves or strongly supports that right, isolates the act that
threatens it, and demonstrates why the harm cannot wait for final judgment. Each
stage of the legal test should be addressed separately.
For the respondent, the
answer should be equally focused. If there is no apparent right, show why. If
the act is authorised by contract or statute, produce the authority and
compliance documents. If damages would adequately compensate the applicant,
explain the measurable nature of the alleged loss. If the applicant has delayed
or concealed material facts, that may also matter because injunctions are
equitable and discretionary.
For the court, reasons are
critical. A ruling should not merely recite Mrao and Giella. It should identify
the asserted right, the evidence of infringement and the distinct conclusion
reached on irreparable harm. That is what makes interim discretion reviewable
rather than impressionistic.
Why
Mrao continues to matter
Mrao endures because it
gives courts a disciplined way to protect rights without deciding cases too
early. It keeps weak applications from freezing lawful activity merely because
litigation has been filed, while preserving the court's ability to intervene
where the documents reveal an apparently unlawful threat.
Its most useful sentence can
be expressed in ordinary language: show the court what right you have, show
what the other party is apparently doing to that right, and support both
propositions with real material.
That is why the precedent
travels far beyond bank cases. Property disputes, commercial conflicts,
family-property claims, intellectual-property cases and many other civil
proceedings still begin their injunction analysis with the same evidential
question. Mrao remains a practical bridge between urgent protection and the
fairness of waiting for a full trial before final rights are decided.
Source
note
This article is based on Mrao Ltd v
First American Bank of Kenya Ltd & 2 others [2003] KECA 175 (KLR), Giella v
Cassman Brown & Co Ltd [1973] EA 358, Nguruman Ltd v Jan Bonde Nielsen
& 2 others [2014] KECA 606 (KLR), Order 40 of the Civil Procedure Rules,
and sections 90, 96 and 97 of the Land Act, with reference to recent 2025 Kenya
Law rulings applying Mrao.
Suggested citation:
Ronald Serwanga, "Defining Prima Facie Cases: Mrao and Injunction Law" East Africa Legal Insight (8 September 2026).