10 (e) But allowing individuals carrying "valid Registration Cards," whose names are not found in the Voter Registration Roll, is subject to two conditions: (i) the Registration Card should be verified through the SMS verification system managed by the NEC. This was not done! (ii) If the person carrying such "Registration Card" is on the list of persons provided by the NEC who have been removed from the Registration Roll, either because of double registrations, or because such persons [are] underage, such persons should not be allowed to vote. Again, the verification was never done by the NEC! Now, whether those who left the polling places prior to the NEC's announcement, allowing every person carrying a voter registration card to vote, were legitimate voters deprived of their constitutional right to vote; or, those who voted, following the NEC announcement, were individuals who should not have been allowed to vote are questions the answers to which will never be known because of the failure of the NEC to perform the statutorily required verifications. The failure by the NEC to comply with the mandatory statutory requirements put into doubt the legitimacy of the elections and creates a cloud of doubt over the elections, warranting a rerun of the elections, and the complainants so pray. (f) Paragraph (d) above notwithstanding, the question remains as to how many persons heard the NEC radio announcement. The presumption is that not many, as those who were not allowed to vote were commuting away from polling places without access to radio at the time of the announcement. Complainants submit that the wrongful and illegal acts on the part of the election officials should not be permitted to disenfranchise voters, as the voter cannot and should not be called upon to police the actions of election officials. As examples of some individuals who were turned away because their names were said not to be on the FRR, complainants give notice that during the trial they will produce copies of voters ID cards of such individuals, and/or their affidavits. 4. The Presiding Officer's Worksheet of the NEC (a) The Presiding Officer's Worksheet of the NEC was not used by the NEC at the various polling places. Among other things, the Presiding Officer's Worksheet would have indicated the starting and ending serial numbers of ballots used at a polling place, making it difficult for ballots in the ballot boxes to be replaced while in transit from the polling place to the magistrate. And the Presiding Officer's Worksheet would have been signed by party agents. In the absence of serial numbers, there is no way of knowing whether the ballots in the ballot boxes were those that were either cast at a polling place, assigned and delivered to the polling places, or ballots that were surreptitiously stuffed in the ballot boxes after polling had closed. The above notwithstanding, [the] absence of the Presiding Officer's Worksheet takes a whole new dimension, knowing that information such as "Number of ballot papers that should be in the ballot box," "Number of the ballot papers taken from the ballot box," among others, are all said to have been copied from Presiding Officer's Worksheet, to the Record of Count. This cast a cloud of doubt over the elections warranting a rerun of the elections, and the complainants so pray. Copies of the Presiding Officer's Worksheet and the Record of Count are hereto attached together, as complainants' Exhibit "C." (b) Strangely enough, the complainants have not noticed any ballot used in the October 10, 2017 [elections], that has serial number. The complainants

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