Notice of Application for Court Orders to bar Chambers Bunny & Steer from Acting in the Supreme Court of Jamaica

CONSTITUTIONAL LAW – The Constitution of Jamaica – Section 13, 19, & 20 of The Charter of Fundamental Rights and Freedoms (Constitutional Amendment) Act, 2011 – Whether the Claimant has locus standi – Whether the States of Public Emergency were imposed for a proper purpose within the meaning of Section 20 of the Constitution – Whether the imposition of States of Public Emergency was reasonably justifiable – Whether the imposition of States of Public Emergency was demonstrably justifiable in a free and democratic society – Whether the imposition of States of Public Emergency breached the

Whether safe system of work – Negligence – Whether Claimant contributorily negligent – Whether cause of accident inevitable – Whether Second Defendant vicariously liable – Credibility of witnesses – General damages principles – handicap on the labour market – Costs of future medical care.

Defendant established by Act with Statutory Constitution – Defendant a Public Education body – Section 3 (1) of Caribbean Maritime Institute Act – Section 28 of Interpretation Act – whether contract between Claimant and Defendant – if contract whether contract breached – Disciplinary measures taken against Claimant – whether right to fair hearing denied Claimant – Credibility of parties

Claimant diagnosed as HIV positive - Claimant re-diagnosed as HIV negative –
medical negligence – Claimant suffering from Post-Traumatic Stress Disorder –
Expert Evidence - Damage

Part 57 of Civil Procedure Rules – Writ of Habeas Corpus ad subjiciendum – principles of Law applicable – Constitution of Jamaica; s. 9, 10, 13, 14 & 20 – The Emergency Powers Act; The Emergency Powers Regulations – s. 30, 33 & 38; Separation of Powers Doctrine/Principle whether Executive breached Doctrine – whether Detention of Petitioners unlawful under EPA & EPR as being in breach of Constitution – proportionality – whether measures under EPA reasonably justifiable.

Evidence – Witness summons and witness summary issued by a party for an opposing party – Validity of witness summons – Application to strike out witness summary – Application to strike out portions of the claimants’ statement of case on the basis that it is a collateral attack on a previous decision of the privy council – Civil Procedure Rules, rules 29.6 (3), 33.2, 33.3(4) and 33.3(5)

Judicial Review Application - Notice of Application filed for Court Orders for Permission
to be joined as an interested party – Rules 56.4 and 54.13 of the Civil Procedure Rules
– whether at Leave stage of Proceedings Interested party can intervene.

Motor Vehicle accident  blameworthiness – Credibility – Road Traffic Act - Damages

Oral Contract for Sale of land – Section 4 of the Statute of Frauds – Deposit made to Vendor – Receipt issued for deposit – Whether receipt sufficient act of part performance – Whether consideration has wholly failed – Promissory Estoppel – Forfeiture of Deposit – Innocent /Negligent/Fraudulent misrepresentation – Caveat against Dealings – Evidence – How to deal with issue of credibility.