Limitation of action – Accrual of cause of action. In the course of the Kenyan emergency group litigation, the Queen's Bench Division held that issues relating to the pre-1954 time bar, and ss 11, 14 and 32 of the Limitation Act 1980 were to be tried preliminarily. However, the application for the s 33 of the Act preliminary issue to be tried as a preliminary issue would be refused.