Wednesday, 1 March 2017

Final Submissions(Closing Argument)

It is more probable that a well tried case will be lost due to a weak, poorly organized final argument than it is that a poorly tried case will be won by an effective argument” [1]

1.0       DEFINITION
A closing argument[2] is the concluding statement of each party’s advocate, or the party himself, reiterating the important arguments for the court. Simply put, submissions can be said to be arguments at the close of the trial or on specific issues that arise during the trial on what a party believes to be the correct legal or factual approach in the circumstances.[3]
This is the stage of the trial where each of the opposing trial lawyers (advocates) or parties attempt to persuade the court by inviting the latter to consider the case advanced and hold in his/her favour (will). Therefore, the ability to make a good speech is key to persuasion in advocacy, with the term ‘advocacy’ deriving from the latin ‘ad vocare’, meaning literally ‘to call towards’.[4]
Advocacy is, then, the art of winning the listener over to the advocate’s cause by persuasive speaking.[5] By and large, lawyers like the Indian pleaders are expected to be good orators. It is for this reason that they are retained and which art strongly comes to life when making a speech to the bench, judge or jury.


2.0      THE AIM/PURPOSE OF CLOSING ARGUMENTS
This is threefold, namely;

          2.1    Persuasion (Rhetorical Dimension of Advocacy).
In an adversarial system, like ours, the findings of fact and the law are based almost entirely on the opposing views put forth by the respective counsels. The judge plays a primarily positive and neutral role therefore highly dependent on the integrity of the lawyers who appear before them. In that regard, closing speeches avail to the litigant, the last opportunity to communicate directly and ultimately convince the court on the propriety (merits) of his approach.
Persuasion entails the psychological element of the case that benefits from human interactions (social economic affairs).[6] In other words, the ability to display the common touch (appeal to emotions) and communicate effortlessly and politely with people from all walks of life. 
A trial litigator will therefore develop a case theory[7] that is convincing, enduring, resilient and consistent with the legal and factual context as well as the available evidence. Then convert your case theory into a story told from the client perspective but in a most coherent (logical) narrative form.
To influence the intelligence and will of the court, one needs to;
a)      Dispel antagonistic feelings or prejudices which will prevent his arguments from receiving a fair hearing.
b)      Build favourable feelings by causing the facts to speak to the will in the same way they speak to the intelligence. The main points to stick out, the subsidiary ones to strengthen key arguments while weak arguments to be avoided altogether.



2.2     Dealing with Unfavourable Evidence
Closing speeches avails an integral platform to essentially deal with evidence that undermines your case concept and trial strategy. This is by approaching evidence from an angle favourable to your client’s case and is best achieved by;
a)      Sealing loop holes in your case.
b)     Carefully maneuvering around pot holes, that is by rendering favourable and plausible explanations for any inconsistencies. Secondly, by contradicting evidence in a more positive (innocent) manner rather than adopting a mere dismissive and hostile fashion. In the alternative, one can challenge the admissibility and relevance of the evidence in question or establish a greater weight of probability on the facts consistent with the client’s case, or even argue that the overall standard and evidentiary burden of proof have not been discharged. This is what is known as toning down weak points by removing their stinging element.[8]
NB.
This helps to improve your image to the court as one comes out as honest, sincere, gracious, magnanimous, appreciative of the entire adduced evidence and helps to focus attention on the real issues to be determined by the court. 

2.3    The Law
Closing speeches allow one to firmly deal with the legal sufficiency of the case. In that regard, formulate precise and sound general propositions of the law which the court is invited to accept.[9] Then offer an array of all relevant authorities and where necessary distinguish them on principles, but always avoid cases said to be ‘on all fours’ with that which is being decided.[10]
In the absence of decided cases, a trial litigator may employ analogies or illustrations to drive his/her point home. Then reiterate the appropriate burden and standard of proof.[11]
In a jury trial, make your points on law succinct (brief) and explain them in straightforward terms without belaboring any points. If in conflict with that advanced by the judge, avoid confrontations for an appeal lies to the appellate court in the event the judge gets it wrong.

In general, in an effort of proving his case and to make the last impression on the court a closing argument should contain the following:
a)      A mastery of the facts and issues of the case.
b)      A reminder of the party’s theory or theme of the case.
c)      A recapitulation of the evidence.
d)     Reference to the standard and the burden of proof.
e)      Reiteration of the relevant law.
To conclude, the closing address avails a litigant, the final chance for parties in trial to persuade the court that their collection of facts, the significance of those facts, and their association with legal principles is to be preferred to that of the adverse party. It is the opportunity to enhance one’s own case and highlight the weaknesses of the opponent’s case.
And even if the decision-maker has already decided the case on the adduced evidence, your closing is still important for it will form the basis of the judgment. For the client, the closing argument shows that their case has been well presented, and if they lose, at least they will comfortably know that a good effort was made.  

3.0  THE NATURE OF CLOSING ARGUMENTS
The closing argument occurs after the presentation of evidence and it may not contain any new information but only use evidence introduced at trial.[12] Different jurisdictions have different rules regarding the closing arguments but generally, the plaintiff has a right to address the court first followed by the defendant with the plaintiff having a right of reply. This is premised on the rule that the one on whom the onus rests must start the closing argument.
 The defendant usually goes second. The plaintiff or prosecution is usually then permitted a final rebuttal argument.[13] Here again the rule is that the argument in rebuttal should be premised only on the law but in certain times the court may allow the rebuttal argument to be premised on facts.    
Ordinarily, with reference to the form of delivery, closing arguments are delivered by way of an oral speech (address) to the court. In Kenya however, the practice is that the arguments are reduced into writing and served upon the opposing counsel or party. Then, time allocation is given for an oral highlighting of the arguments in an open court or at the Judge’s chambers.
This practice came about due to the congested diary of the courts with the object of saving time towards expeditious conclusion of matters. Written submissions also encourage the judge to make notes on your material for further cross reference. They also help the advocate order their presentation in court in a logical and systematic manner.
However, the procedure has been held to be irregular, especially in criminal cases. The case of Henry Odhiambo Otieno v Republic[14] is important in this regard. The Court stated:
“…this case shows the dangers inherent in a situation where both the court and counsel make shortcuts to finalize matters they are seized of. It is a good thing when courts and counsel show a desire to urgently conclude matters. However, where as in this case justice is compromised, the practice of making shortcuts is to be deprecated.”
In that case, the defence counsel filed written submissions which the trial court considered in making its judgment. The Appellate court was doubtful that the Accused had been given access to the written submissions.
The court relied on the case of Salim Dean v. Republic[15] where it was stated that:
“The Criminal Procedure Code provides a precedent for the making of submissions in the court. In no part of the legislation is there a mention of written submissions. A presiding officer of the court is expected to hear orally such submissions as both sides in a criminal case wish to make and to seek clarification of such submissions as found necessary, in order to appreciate each side’s case before delivering his opinion. The accused person is also supposed to hear those submissions and has the right to clarify any point raised or to object to its being raised where he considers it necessary for his own benefit. Written submissions deny the accused that fundamental right. It is fundamental because were it not so the drafters of the constitution would not have entrenched it in the constitution.”
The form notwithstanding, submissions are most likely to succeed if properly structured and well delivered because the judicial officer is likely to be persuaded, if the argument is delivered in a systematic and logical manner rather than as a confusing mixture of facts and opinions.

4.0  THE SCOPE OF CLOSING ARGUMENTS
There are ethical and legal limitations to the contents of a closing address:
·    The closing argument should be limited to the evidence led at trial- new evidence or information not covered during the trial cannot be introduced at this stage. This means that counsel may not bring out any fact not actually mentioned in the pleadings or the evidence of the witnesses.
·    It is improper for counsel to exaggerate. For instance, it is improper for counsel to suggest to court that a witness was an entirely satisfactory witness, in all respects when clearly this was not the case. It is however proper to make concessions about imperfections in the testimony of his/her own witnesses. This, because in an adversarial system, the findings of fact are based almost entirely on the opposing views put by counsel with the judge playing a primarily passive role with the courts highly dependent upon the integrity of the lawyers who appear before them.
·    To ensure adequate treatment of the client’s case by upholding his interests, and in the criminal case, by ensuring that the prosecution discharges its onus, and not to fabricate any defences, or to assist the prosecution case in any way whatsoever.
·    Not to inquire into the truth of the client’s instructions at the trial stage.
·    The advocate has no duty to disclose facts to the court or to the opposing party which will assist the opposing party but ought to reveal all relevant case laws and statutory provisions within his knowledge, because they have sworn allegiance to uphold the law by virtue of their profession  and as officers of the courts. However, the prosecutor must engage scrupulous fairness in prosecuting a criminal case.



5.0  THE CONTENT AND STRUCTURE OF SUBMISSIONS
The whole of the client’s case pivots around the content and structure of submissions with the various approaches, inter alia, including;

1.      Point of view                 2.    Issue                        3.  Conclusion                
    Reasons                       Rule                             Rule
    Evidence                     Application                   Explanation                               
    Summary                     Conclusion                    Application
                                                                          Conclusion
The approach in clause 3 is more appropriate for the structure of a written submission and which will be dealt with in this paper but the manner and terminologies differs with that of Legal Writing and Drafting skills. Where as, clause 2 caters fully for legal opinions, clause 1 appropriately suits oral submissions promptly made during the heats of the trial process. 
That said, a closing speech generally consists of three parts, namely;

5.1  Introduction/ Exordium/Proomium
It is the introductory paragraph(s) of the speech, and usually the first sentences carry the main themes of your case. This however should be a precise and captivating conclusion of the overall case. 
The introductory part also contains a brief summary (background) of the facts of the case purposely to pave the way for the statement. One should state the facts he wants the judge to find but caution should be taken to avoid restating or reciting facts.[16]
The purpose is to arouse or cultivate the court’s interest and attention by exciting favourable feelings (removes prejudices), sets the stage for magnifying issues by lifting them to a higher plane or reducing their importance and ultimately making the audience favourably disposed to your case.


5.2  The Statement
This entails the statement and explanation of what needs to be proved, that is to say, the facts in issue. The statement should cover the following;
a) The issue:
These are legal issues that require proof. Brings the judges attention to those issues which are common cause and those which are not in dispute, due to:
·         Prior arrangements between the parties;
·         Formal admissions made before or during trial; or
·         Evidence of both parties on the aspect being identical.
Most importantly set out the factual issues upon which the court is required to make a finding.
b) The onus on the issue:
Draw the attention of the court to the overall onus and the appropriate standard, but it may be necessary to highlight any aspects of the case where the evidentiary burden of proof may have shifted to the other party.

c)      The legal test applicable to the issue:
This is the law or legal principles applicable to the issue. Distinguish the elements of the law that are applicable to the issue and which should be proved for the court to decide on the case. These can be found in case law, legislation or legal writings on the subject.

d)     The Proof
It entails arguments in support or in refutation of a trial case. Thus, one ought to play the devil’s advocate by anticipating likely arguments to be advanced, objections to its validity or setting up a counter argument. The proof includes;

e)      Agreed facts:
Begin with facts which are not in dispute and demonstrate to the court that those facts are more consistent with your client’s explanation of the matters than the explanation put forward by the other side.
f)       Summary of relevant evidence:
Summarize (only a few lines per witness) the evidence that the court has to consider to decide the case. Objects, documents and other items of evidence are discussed in closing argument with reference to the witness through whom they were handed to court. The essence is to show the actual facts in issue through the tool of cross referencing.

g)      Evaluating the summarized evidence:
This is the crucial part of the submission. It is an opportunity to persuade the court that your client’s version of the facts should be awarded preference over that of the opposing witnesses. First, analyze facts in issue that require proof, and then discuss the adduced evidence to emphasize the strong points in your case while highlighting the weaknesses inherent in the opponent’s case.

Highlight and analyze any instances of contradictory evidence with other witnesses, corroboration of the relied evidence by drawing the judge’s attention to oral evidence which has been supported by the documents rather than evidence which is neither supported nor indeed contradicted by what has been contained in the documentation or are indications of untruthfulness or exaggeration. Highlight the inherent probabilities when considering the witnesses’ versions, the demeanor of witnesses as well as the weight to be attached to objects and documents handed in by witnesses.

Make an assessment of the witnesses, their testimony and other evidence as being truthful, untruthful, mistaken, consistent, reliable or unreliable. It is at this point that counsel may suggest inconsistencies in the witnesses’ evidence on crucial aspects such as the explanation of distances, description of lighting, explanations as to time or description of a person.

Overall, a sound knowledge of the rules of evidence in respect to the admissibility and relevance of evidence is very essential to successful advocacy so as to deal with any objections to your evidence which may be equally un anticipated, and if unfounded, must be promptly refuted before the court rules that some vital evidence is inadmissible.[17]

After successfully tying the facts in issue persuasively to the evidential facts and proofs (whether from an affidavit or oral evidence), then conclude on the facts in the case by drawing your conclusions from the evaluated evidence.

h)     Apply the legal test to conclusions of facts and the overall onus of proof
Integrate the facts found to be proved with the relevant legal principles and determine whether the onus (burden) of and standard proof has been achieved. Explain how your facts best fit the legal requirements. Sometimes the law is clear and settled on a point in issue, but at times the law is unclear, hazy and most puzzling.

5.3  Peroration/Climax
The part where a litigant applies a finishing touch, gloss or veneer to the speech by developing a most convincing rational argument founded in law and the facts of the case aimed at disposing the case in your client’s favour. It entails asking or urging the court to make a finding in favour of your client and set out the relief sought.

The role of the climax is to bring the speech to an end and drive home the entire essential arguments while arousing the feelings to which the facts of the case naturally give rise to. For instance, the desire to see justice done where the accused person, is proved beyond reasonable doubt to have committed a deliberate heinous and callous murder.

OVERALL, the characteristics of a good speech are threefold;
  1. To Interest, especially by striking the right note in the introduction and by vividness in the narrative, and also by grace of style and delivery;
  2. To Prove, by clear exposition and arguments, which appeal to the intellect;
  3. To Convince, by breaking down the resistance of the will and rendering it favourable. The process starts with the note struck in the introduction, is heightened by the narrative, and brought to a climax in the peroration.[18]

6.0  TECHNIQUES
How does one give an effective closing argument? There is no universally accepted mode or technique for the delivery of the closing argument. The techniques are as varied as advocates themselves. The advocate has more freedom and control over closing arguments than he has over any other aspect of the case. Consequently, It should be his favourite task; a task that bears his personal stamp, reflective of his or her true inner self. The closing argument is when the artistry of persuasion is marshaled on behalf of the client’s case. Most of the persuasive techniques used in opening statements can be used in closing arguments. There are techniques used in closing arguments that make it most effective.

  1. Do not memorize
It is a mistake to write and read a closing argument. The most effective arguments are delivered from an outline. It is better to memorize thoughts than words of your closing argument. If you try too hard to memorize every word of your closing, you will have a hard time surviving fifteen minutes.  Judicial officers will be more persuaded if you are more relaxed.  In addition, you will not have to worry if you missed certain words or sentences because you will be able to focus on the larger picture of your argument.  You may bring notes, but you will want to keep them to a bare minimum.

  1. Movement
It is important to use a certain amount of body and hand movement. These capture and sustain the attentiveness of the judge. Gestures can be used for emphasis especially on the salient features of your case. Body movements can also be used for transition. For example, pausing and taking a slight break will alert the judge that you are about to change subjects.

  1. Verbal placing
Delivery is a matter of elocution and voice development. The effective control of the pace, pitch, tone, inflection and volume of the closing speech forms an imperative persuasive tool. Also avoid speaking too quickly and too loudly. Pacing of speech can be used to convey passage of time, distance and intensity.

  1. Emotions
There are varied opinions abut the use of emotions during closing arguments. Many lawyers are for the use of emotions, while many others are not. The best approach is to save it for the times you are discussing the many dimensions of your case. There will be instances in trials that virtually call out for an outward display of feelings because the absence of emotions may be taken to mean the lack of belief in the righteousness of your client’s case.
Overall be pleasant, accept criticism and don’t be quick to lose your temper However, avoid personal opinions and uncalled for humour as this may not only irritate the court but as well trivialize your client’s case.

  1. Visuals
These are hardly employed in Kenya despite being very effective during closing arguments. The advocate is free to create visual displays for vivid and illuminative purposes. Physical evidence other than documents can be used during final arguments to recreate the investigation process, more so crime scenes in criminal cases. The only restriction on using visual aids is that they must be derived from the evidence adduced during the trial.

  1. Headlines
These may take the form of a simple statement, rhetoric questions or short enumerations. These can be more effective when used with visual aids. This technique helps bring out coherence and unity in a closing argument.

  1. Simple, Active language
This should be used in argumentative form. There is a strong temptation during final argument for using judgmental or conclusory terms like brutal, deceptive, unfair, naïve etc.

  1. Themes and Theories
A closing argument is logic, evidence, and emotion brought together. It is important to develop a theme or theory of the case earlier on in the trial and which are amplified in the closing argument in such a manner that the court accepts it and sees it as what really happened. It is important to adopt and commit to a theory.  Then argue the theory persuasively and with conviction. However, do not develop hypothetical standards but unique standards for the judge to apply in the case.

9.      Appearance
Your appearance is an important part of the impression you create as an advocate. It can add or detract from your credibility. Make the court interested in what you are submitting on and not your appearance. Be modest.


10.  Communication and organization skills
Artistry is a combination of tacit knowledge (tact, personal knowledge shaped by experience, knowing in action), technical knowledge of the law (knowing what-classroom experiences) and cognitive skills (practical skills or experience carved out of experience). However, all these will come to naught if the advocate lacks the necessary communication and organization skills in case preparation, management and presentation.

Communication is the life blood of a trial lawyer; therefore a sound command of the English language both spoken and written is a must. Therefore, a litigant ought to select and employ a simple, clear, unequivocal, authoritative, forceful and persuasive language but within an orderly presentation of the salient points of the case.[19] Communication also entails knowing the court terminologies, use of courteous language like: if it may please this honorable court; as the court pleases; it is my humble submission, etc.

Mould the content of your speech to be as pleasing to the court as possible and it is a sound rule to be as brief as possible as is consistent with a full preparation of your arguments.

11.  Style of delivery
An accurate and varied style of delivery will most likely captivate the attention of the court. Careful use of original figurative speech, similes, pace, metaphor, repetition and the adoption of powerful imagery is vital to the advancing of your themes and creating a lasting and interesting picturesque.[20]

Use the narrative tool to explain issues and advance themes and strategies in a most vivid, illuminative and imaginative way that brings out the character and emotional behavior of the chief actors. Charming Varied, graceful style and pleasant and varied delivery relieves the monotony of every day’s language. And the employment of transitory words or introductory phrases ensures a smooth well balanced speech.

The best style to adopt in making a speech is your own. While there is nothing wrong with picking useful techniques and phrases from other experienced advocates, an attempt to imitate the style of another is doomed to fail-cultivate your own style rather than ape others in order to impress the court. This brings you out as sincere and unaffected.

Sincerity not necessarily to believe what your client has told you but to suspend any disbelief he has once he has clear instructions about the way the case should proceed and must present his case in a manner which makes it clear that it is a version of events sincerely put forward to the court.
All in all, allow the facts to speak for themselves but do avoid hyperbole or exaggeration.

There are other factors that would also contribute to an effective closing argument:
·         Prepare your case file: label your notes of each witness’s evidence and file them in the sequence that the evidence was given. Bring any case authorities you may need to rely upon to court and make enough copies to be supplied to the judge and your opponent during the submissions. Paginate the submissions (if written) for quick reference by the judge.
·         Anticipate your opponent: Where there has been adverse evidence, you must deal with it. Present the facts and evidence favorable to your position, but also embrace the bad facts while addressing your weaknesses. Expect your opponent to focus upon any and every limitation in your client’s case. Expertly package the weaknesses so that they seem relatively unimportant. Bad facts will not simply go away, but explaining them away defuses the opponent's arguments and reinforces your credibility.
·         Interact with the judicial officer: Aim at involving the decision- maker in your closing arguments so that you are responding to their concerns rather than talking at them, in the hope that your priorities and theirs are the same. Be alert to any spoken or unspoken hints about what the decision- maker wants. It is not good persuasion to make a closing address as though the judge was an empty bottle into which you can pour your arguments, which finally float above any other arguments put by opponents.
By the time you utter the first word of your closing, the judge has learnt all about the case. Undoubtedly, the judge has made decisions, if not about the final outcome, then about much of the evidence. It would be a wasted effort to be eloquent about matters where the court’s mind is made up. It is better to be eloquent about those issues where the judge is wavering. Only the judge can say what those unresolved issues are: so ask.
·         As the plaintiff’s advocate or the prosecutor save some of your best one-liners and most telling points for the last when the defendant lawyer has sat down and can no longer rebut what you are going to say.
·         Damages - After completely discussing the elements of the case and your client's right to prevail in the lawsuit, move on to discuss damages. This is extremely important and cannot be rushed or discussed in a haphazard or unorganized way. Conversely, if representing the defence, the argument should focus more on the liability aspect of the case.
6.1  A CLOSER LOOK AT THE CIVIL AND CRIMINAL ASPECTS
6.1.1        Criminal Cases
a)      The Prosecution Case
Simply put, this is the case of the Republic (State) as against the accused person who is alleged to have committed criminal offences.[21]
The essential elements of the offence are contained in the charge sheet. For example, the offence of theft would allege the defendant as having; a. dishonestly b. appropriated c. property d. belonging to another e. with the intention of driving of depriving the other of it permanently.
The prosecutor has to probe legal issues that require proof, anticipate possible defences or loopholes in his case and analyze facts that he must prove to obtain a conviction or to impinge the defence case.[22]
This will allow the prosecution to focus its mind on the facts to which the evidence must be directed by identifying evidence to prove facts in issue.

b)     The Prima Facie Case
This happens where the prosecution adduces, with respect to each essential element of the charge, evidence on which the court would be entitled to find such element proved if the accused person was not entitled to his defence. That notwithstanding, the establishment of a prima facie case is not enough to secure a conviction, because the defence is entitled to argue that the overall burden of proof has not been discharged or establish possible defences consistent with the accused person’s innocence.

However, once the prosecution has established a prima facie case, the defence runs a serious tactical risk in not calling evidence to rebut it, not because the defendant is called upon to prove his innocence (which would be contrary to the rule in Woolmington’s case) but because the court may exercise its entitlement to accept the uncontradicted prosecution evidence.[23]

c)      The Submission of No Case to Answer
A submission of no case to answer is made at the close of the prosecution case, that is, before the presentation of the defence case. At this stage, the bench determines whether the prosecution has discharged its burden of proof. And if the prosecution closes their case without adducing any evidence capable of proving an essential element of the offence charged, the bench will uphold a submission of no case to answer, because the burden cannot be discharged. A submission of no case to answer may also rest on a point of law.

However, a litigant ought to exercise great caution because a hopeless ill-founded submission may unnecessarily irritate the judge and thereby adversely affect the client’s case. In that regard, always plan for the possibility of the submission failing in whole or part for you are likely to face a difficult trial having antagonized the bench. Even so, the decision is a question of judgment that will become much easier with experience.

The procedure is for the Defence counsel to move the court on a matter of law, and in the case of a jury trial, the jury retires.  The Defence counsel then outlines the submissions citing relevant authorities but based on the insufficiency of the adduced evidence. The prosecuting counsel responds to the submission, Defence counsel replies, with the judge set to deliver a reasoned ruling.
d)     The Concept of Ideal Closing Speech
This is the closing speech which you, as the Defence attorney, would like to make, if the evidence given in your case were actually to justify it. Even though this concept sounds premature, it is nonetheless most effective in criminal cases, because the prosecution have no right to a closing speech, except for the limited purpose of responding to points of law.
The object of the ideal closing speech is to compose the strongest possible closing speech; the most persuasive argument to the court that you can imagine on the basis of your client’s instructions thereby serves to focus your mind on the evidence which would be required to put you in a position to make it. One should however create room for flexibility because the concept of ideal closing speech does not imply that a litigant should strictly follow it to the letter by blindly making it the ultimate closing speech. It merely serves as a useful guide or summary on the direction in which your trail preparation would take for effective presentation and delivery of your case.

This is in terms of focusing your thoughts, inter alia, on how to approach the prosecution’s case, evaluation of the evidence to be adduced, what witnesses to call and which ones to cross examine, and how to actualize your strategies and themes. In that regard, when amended to factor in what transpired in court, the technique provides an excellent framework for the speech you will make. This bearing in mind that the nature of most defences appears quite clearly from the path taken in cross-examination. Most importantly, one thing that should emerge with some clarity from your ideal closing speech is a picture of the witnesses you will need to call at trial.

Conversely, the opening speech is the best opportunity for the prosecution to be persuasive by making a speech of brevity proportionate to the simplicity of the case.

e)      The Plea-in-Mitigation         
A plea in mitigation is an appeal to the court to exercise favourably its discretion in passing sentence. This submission is made by Counsel to reduce the expected severity of the punishment to a lenient one. The aim of an advocate during plea-in –mitigation is to present the circumstances of the offence and the background of the offender in such a manner as to minimize the penalty or better still acquit your client. On the aspect of the background of the offender, you can present facts that would exude the court’s sympathy to your client.  For instance that your client is the sole bread winner for his family or that they are of old age or sickly.
Therefore, it is part of the Defence attorney’s duty to persuade the judge to sentence the accused in more lenient terms than the judge had prior resolved to. Persuading a court to hand an appropriate sentence requires the same approach as that of contested cases.  Evidence may be called with both examination-in-chief and cross-examination. There can be exhibits, such as diagrams, photos and character references and, there can be competing arguments from the Prosecution and Defence.

Defence counsel should always be prepared to deliver a plea-in-mitigation no matter what the plea is. If the accused pleads guilty, the counsel has to do everything possible to reduce the expected severity of the punishment by negotiating with the prosecution for a lesser term (plea bargaining) or in the alternative, preparing and delivering an effective plea-in-mitigation. If the accused pleads not guilty, the lawyer must also be prepared to deliver a plea-in- mitigation in the event of a conviction.

There are a number of factors that the court takes into consideration in passing sentence such as the goals of sentencing, specific circumstances of the offence and the offender, and public opinion. In addition to these factors, are the key elements of contrition and remorse. If the offender demonstrates to the sentencing court that they have a real sense of guilt and regret their criminal actions or omissions, then the penalty will most likely be lesser than if the offender lacks any such sense of contrition and remorse.

However, to merely tell the court that your client is sorry states no more than the obvious. Of course your client is sorry – sorry that they got caught! Being sorry reveals nothing about their understanding of the wrongness of their conduct or their need to express regret. Real contrition and remorse is shown by the responsible actions taken by the offender before the plea is made.

A persuasive plea-in-mitigation is one which does not gloss over points. By setting out both the elements and the supporting evidence you can avoid the common error in which bare assertion is asked to be both argument and evidence. Consider the following submission based on the issue of contrition:
‘My client is very sorry for what she did. It was out of character and she realizes she has done the wrong thing.’

Compared with:

‘My client is a young professional who forgot her own condition as she tried to persuade a friend not to drive. She has learnt her lesson: when she has a friend in need, she calls a taxi and refuses to let the friend leave until the taxi arrives.’

The second version is more persuasive because it goes into the detail. It isn’t simply a ‘heading’ but rather paints the picture. It gives the judge the facts that demonstrate contrition. The first version sounds more like an excuse. Of course, in some situations the devil is in the detail and it is wiser to skim over that detail and not go into depth; for example, as to particular aspects of your client’s criminal history.

As a tactical plan avoid stating the plea when the court is expecting its daily share of usual excuses from offenders, which the court has heard time and time again. It would be better to tell the court in advance that the plea will take a bit longer than usual and that you will be calling evidence. The need for extra time means that your case will be put at the end of the list, thus availing enough time for the court to appreciate ‘how’ and ‘why’ the case is distinct from the rest.

Importance of a Plea-in-Mitigation.
  • It can be called to avoid potential disqualifications or to reduce the number of penalty points or periods of disqualification.
  • It assists the court to determine the seriousness of the offence and reconcile the public safety by reflecting on any relevant personal information or past record of the accused with the discretion of reducing the sentence.
An effective plea-in-mitigation will entail the following:
a)      The Advocate must understand the theory of sentencing and the importance of researching on any applicable sentencing guidelines. For instance, researching on the sentence the client is likely to face.
b)      The Defence attorney must have in mind a realistic sentencing objective, having regard to the theory behind sentencing and having considered any applicable sentencing guidelines.
c)      The advocate ought to have good advocacy skills.

Preparing a Plea-in-Mitigation
The advocate will need the full instructions from the client, as there are a couple of things you must attend to before making your plea-in-mitigation.
·    You must check if your client has a criminal record. The prosecutor will have a copy of that record, and the court will get a copy during the sentencing. Check with the prosecutor as early as possible. Do not take your clients word that s/he has no criminal record because a plea that is largely based on your clients good character will quickly sink without a trace, the moment the prosecutor refers the court to an earlier occasion when that good character slipped away.
·    Also, explore your client’s ability to pay a fine or make a donation to a charity. Is your client able to pay immediately or only by installments over several months? Be prepared to tell the court of your client’s capacity to pay.

During the arguments in mitigation, the advocate should also:
i)                    Concede the aggravating features of the case.
The counsel will need to look at the law and at the prosecution evidence to decide whether any charges can be made good by the prosecution. Counsel must be aware of the prosecutor’s version of the facts having considered the pretrial disclosure or evidence and having listened to the prosecutor’s submission to the court outlining the circumstance of the offence.
ii)                  Balance the theme of the case
The advocate must be aware of the sentence the court can impose for a particular offence. He should therefore be in a position to assess the balance of aggravating and mitigating features in the offence and arrive at an assessment of the seriousness of the offence. Put yourself in the position of the court and consider what sentencing objective the court is likely to follow and this will help the advocate arrive at a realistic sentencing objective which gives you the basis upon which to build your plea-in-mitigation.
iii)                Negotiating the lowest charge.
Negotiations can begin in a number of ways.  In the superior court, the defence will often send a written submission to the Director of Public Prosecution suggesting that a lesser charge should be given. This is called plea bargaining.

Structuring a Plea-in-Mitigation
There is no predetermined structure of a plea in mitigation. The following are the possible factors an advocate might have regard to;
a)      If your client has pleaded guilty, introduce yourself to the bench and introduce your client
b)       Acknowledge the Prosecution’s outline and presentation of facts. Further highlight the prosecution facts you disagree with.
c)      Use a pre-sentence report. This outlines the personal history of previous convictions, circumstances of the present offence, details of the Defendant’s response to and insight about his situation (usually based on an interview with the convicted person) and a recommendation in relation to appropriate sentencing
From decided cases, it is paramount that the court considers the plea in mitigation in passing sentence. In the case of Ismael Juma v. Republic,[24] the High Court sitting as an appellate court, found that the trial magistrate had not taken the plea in mitigation into account when passing sentence and accordingly reduced the sentence from seven years to four years.

In another related case of Ali Iregi Githinji v Republic[25], the court also upheld the ruling that the court is mandated to consider material factors in mitigation before passing sentence. The court stated thus:
“I have perused the record of the trial court and nowhere did the learned magistrate give recognition of the fact that the Appellant had pleaded guilty to the charge therefore saving the court’s time. The learned trial magistrate did not recognize that the Appellant was a young person. The court gave more weight to the seriousness of drug cases generally. In doing so I find that the learned trial magistrate overlooked material factors and that these factors dictated a less severe sentence than the one imposed. In those circumstances I find that the sentence of 50 months imprisonment was excessive and manifestly harsh having considered the Appellant pleaded guilty, was a first offender and that the amount involved was 19 rolls of bhang and therefore not enormous…”
However, sentencing upon a plea in mitigation remains the discretion of the trial court which ought not to be interfered with by an appellate court unless it is evident that the lower court has acted upon some wrong principle or overlooked some material factor or the sentence is manifestly excessive in the circumstances of the case.[26]
Where a party omits to give a plea-in-mitigation, he has himself to blame. In the case of Musa Juma Simiyu v Republic[27], the Appellant when asked what he had to say in mitigation, stated that he had nothing to say and was thereafter handed a ten year sentence. On appeal he contended that the trial court had not considered his mitigation of pleading guilty to the offence. The appellate court dismissed the appeal noting that as the appellant had not put in a plea-in- mitigation, he could not prove that the trial court had failed to take into account some relevant factor in handing down the sentence.

6.1.2        Civil Cases
There are no unique features concerning submissions of a civil nature save for due regard to the standard and burden of proof.[28]
Nonetheless, an effective closing argument is an essential tool for the plaintiff’s trial attorney to maximize damages for his client. During the summation, all of the evidentiary pieces should be brought together and the case should be presented in a strong, fluid, and persuasive manner. All points that help prove the elements establishing the theory of the case must be fully explained. The closing should be performed in a simple, yet precise way

7.0  CONCLUSION
In conclusion, as earlier alluded to, there is no one way of delivering submissions or closing arguments. The techniques involved are varied and therefore ought to bear the advocate’s own stamp. He should own it. The discussion contained in this paper however can hugely assist a litigant to deliver his arguments. The importance of the closing argument cannot be over emphasized. This is a huge factor in the final determination of the case. The closing argument goes a long way in either making or breaking the case and as such, careful consideration should be given to it.




Viewed this way, submissions should be formulated on the same lines of thought as the Judge would, for they form the foundation of the judgment of the court.
[2] Also referred to as; closing speeches or closing address or submissions.
[3] Submissions are not limited to the closing of the case; there are other opportunities before, during and after trial. For instance, in civil cases, submissions are also made when there are interlocutory applications.
[4] See; P. Murphy & D. Barnard, (1986) Evidence & Advocacy (2nd Ed., Blackstone press, London.) p.
172. (Paraphrased.)
[5] Ibid.
[6] Examples include cultural traits, attitudes, forensic taste, the mood of the court, etc.
[7] This while bearing in mind that there shouldn’t be a lot of divergence between your client’s case and that of the opponent’s.
[8] For instance, one can challenge the relevance (‘if it is logically probative or disprobative of some matter which requires proof’ per Lord Simon of Glaisdale in DPP .v. Kilbourne [1973] AC 729), admissibility (qualities which evidence must posses as a matter of Evidence Law), and weight (cogency of the admissible evidence) of evidence, failure to meet the required evidentiary burden of proof (does evidential facts tie to inferences that proves the facts in issue?), or by tendering a vivid picture of a reasonable, realistic and practicable possibility consistent with your client’s innocence.
[9] Avoid restating verbatim the laws as laid down in the statute save where necessary. 
[10] Use cases that enunciate principles for the court is not concerned with the facts of the cases however similar except where they throw light on principles.
[11] The burden of proof lies on the party who must prove an issue in the court. In civil cases, it lies on the one who alleges a fact and who must prove it in order to succeed in establishing his claim or defence while in criminal cases; the prosecution bears the burden of proof (Woolmington .v. DPP [1935] AC 462 HL(E)). The standard of proof, on the other hand, defines the degree of persuasiveness which a court must attain before a court may convict a defendant or grant relief in respect of a cause of action, as the case may be. The standard of proof in civil cases, and in the words of Lord Mansfield, is based on a superior number of probabilities (preponderance of probabilities) while that of criminal cases, is beyond reasonable doubt (not beyond the shadow of doubt, i.e. certainty, but must carry a higher degree of probability. See Lord Denning’s judgment in Miller .v. Minister of Pensions [1947] 2 All ER 372;). (For a detailed explanation, see generally; P. Murphy & D. Barnard, supra note 3, at pp.3-7.)
[12] Obtained from <http://en.wikipedia.org/wiki/Closing_argument> as at 10th August 2009
[13] ibid
[14] [2006] eKLR.
[15] [1966] E. A. 272
[16] Also, avoid dwelling too much on facts. Deal with the real issues and capture the whole case.
[17] Trial preparation is certainly necessary to deal properly with all the problems which can be foreseen or unanticipated.

[18] See; John H Munkman. (1999). The Technique of Advocacy. New Delhi: Universal Law Publishing Company, , p.152
[19] The choice of diction plays an integral part in a closing speech.
[20] However, be very careful because dead and worn out figurative speech may irritate a listener whose taste is critical.
[21] See the Penal Code, Chapter 63, Laws of Kenya.
[22] The required standard and burden of proof in criminal cases have been discussed earlier; supra note 11. 
[23] The words of Murphy and Barnard, supra note 3, at page 4.
[24] [2005] eKLR
[25] [2006]eKLR
[26] Sayeko v Republic [1959] KLR 306
[27] [2007] eKLR
[28] Supra, note 11.

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