Again, the uncontroverted evidence is that there was no official list issued. In the circumstances, it would have been impossible to ascertain that the persons applying for ballots were qualified to vote. There was no way of ensuring that voters were not being impersonated. Fundamental to the concept of free and fair election is the principle of one man one vote, same man same vote. C The evidence adduced as to the circumstances under which the election was conducted in this polling division undoubtedly undermines that fundamental principle. poll in^ - Division 57 Constable Richard Johnson, a member of the Jamaica Constabulary Force assigned to this polling station on election duty had the amazing experience of c; witnessing an indoor agent of the Jamaica Labour Party voting openly and on behalf of electors whom he had sent away from the Polling Station. This contravenes section 93 of the Representation of the People Act which enacts that no person shall apply for a ballot paper in the name of ansther person. GROUND 3 "That there was an upsurge of violence and/or irregularities during election day in one or more Polling Divisions in the Constituency and or in the

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