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Educational sample. Replace bracketed fields using your evidence.
REPUBLIC OF KENYA
IN THE EMPLOYMENT AND LABOUR RELATIONS COURT AT NAIROBI
CAUSE CIVIL SUIT OR APPLICATION NO [correct reference]
[CLAIMANT PLAINTIFF OR APPELLANT] v [RESPONDENT OR DEFENDANT]
EVIDENCE OR COMPUTATION SCHEDULE
1. Item 1: Initial appointment and confirmation letters, [dates and pages], establishing the original duties and employment terms. Item 2: Each transfer or role-change letter in chronological order, [pages], identifying when the duties changed.
2. Item 3: Written revised job descriptions, communicated targets and acknowledged performance agreements, if they actually exist. Record the relevant role and assessment period for each. Where no such record is available, state that accurately rather than creating a replacement.
3. Item 4: Minutes of the 10 and 24 March review meetings and the corresponding emails, [pages]. Item 5: Actual scorecards, deposit reports and commendation records, [pages], distinguishing measured results from opinions about performance.
4. Item 6: Show-cause notice, response, hearing invitation, representation notice, minutes and appeal record, where present. Identify missing records explicitly. Item 7: The termination letter and proof of receipt, followed by final payslips and payment records.
5. For every item provide date, author, description, page range and intended authenticating witness. File the chronological paginated copies and serve the other party under the applicable rules and directions. Listing a document does not itself admit it in evidence.
DATED at [place] on [date]. Signed [party or advocate]. DRAWN AND FILED BY [name and address for service]. TO BE SERVED UPON [each affected party and address].
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An advocate confirms availability, scope and fees before accepting your matter.Educational reconstruction from a reported decision. Newly drafted sample, not an original filing or a matter handled by our team. Identifying details are replaced with bracketed fields. Verify the facts, law, jurisdiction and court directions before use.
Use and evidence notes
This schedule supports a pleaded issue; it is not a new originating process or proof by itself. Give dates, authors, document pages, authenticating witnesses and transparent calculations. Label missing or disputed evidence accurately. Current costs and rates need current proof. Obtain leave or directions for supplementary material where required, serve it and avoid duplicate recovery of paid heads. Applicable rules: ELRC Procedure Rules 2024, amended by Legal Notice 78 of 2025; verify current court directions.
Supporting material schedule: [document date]; [author or custodian]; [description]; [bundle page]; [authenticating witness]; [admission or permission]. Attach only genuine available records and mark missing records accurately.
Source facts and limits of the decision
A bank employee moved through several roles after an initial 2013 appointment. A January 2017 letter changed his role effective 6 February. Performance was reviewed on 10 and 24 March and employment ended in April for continued underperformance. The bank did not produce updated job descriptions, key performance indicators or an actual scorecard. Its HR witness acknowledged no show-cause letter or disciplinary hearing. The exit salary was KSh 145,000.
The Court found both substantive and procedural unfairness and awarded nine months of salary, KSh 1,305,000, subject to PAYE, with costs and interest from judgment. Severance was refused because dismissal was not redundancy. KSh 43.5 million for twenty-five future years was refused. The reported reproduction carries a DRAFT watermark but includes dated final orders and online delivery; obtain a signed court copy before procedural reliance.
Employment Act section 10 requires written employment particulars and revision when they change; sections 41, 43 and 45 govern fair termination. A review meeting is not automatically a section 41 hearing. Sections 49 and 90 govern remedies and limitation. This historical claim cannot be revived by copying a sample. Use the ELRC Procedure Rules as amended in 2025 and authenticate the final judgment.
Read the original reported decision: [2026] KEELRC 938 (KLR) — 17 April 2026
The original decision may identify participants. The specimen replaces their identifying details. The judicial text reproduced on SheriaHub was read, including the reasons and final orders. This is a reconstruction from the reported decision, not a copy of a signed court filing. Where publication metadata and the judgment differ, the judgment controls. Check later appeals and the applicable version of procedural rules before relying on the case.
Related law and procedural rules
Constitution of Kenya · Employment Act · Employment and Labour Relations Court Act
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