20.
21.
22.
23.
24.
25.
26.
There was no basis for the court to conclude that the postponement of the elections aected voter
turnout as a consequence of which the 1st petitioner, alone, as a presidential candidate suered a
disadvantage. The nature of the ballot being an individual decision and secret, there could be other
variables to which the turnout in the named units could be attributed. The 2022 General Election
recorded one of the lowest turnout since the reintroduction of multi- party political system, some
30 years ago. If there was a low voter turnout, it aected all the six categories of candidates and its
explanation lay elsewhere but certainly not a calculated suppression. There was no nexus between the
postponement of elections and voter turnout in the aected units, the claim was a red herring. There
was no proof that the postponement resulted in voter suppression to the detriment of the 1st petitioner.
A person who asserted a fact had to prove it. The burden was cast upon the 1st petitioner to demonstrate
that there were instances of ballot stung of such a magnitude as to justify the nullication of the
presidential election. Ballot stung, which was the illegal addition of extra ballots, was a type of
electoral fraud aimed at swinging the results of an election towards a particular direction. Not a single
document had been presented by the 1st petitioner to prove systematic ballot stung. A gure of
33,208 votes relied on in that claim was based on unproven hypothesis that since the number of votes
cast for President was higher than those for the other positions then, without more, it had to follow
that there was fraud.
Fraud was a serious criminal oence and had to be proved beyond reasonable doubt. Under section 5(n)
of the Election Oences Act, it was an oence for a person to vote more than once in any election. IEBC
had proered a plausible explanation for the vote dierential. There were categories of voters who only
voted for the President, such as prisoners and Kenyans in the diaspora. There were an insignicant
number of stray votes, whose combined eect could not justify nullication of the election.
A general election in Kenya comprised of 6 dierent and separate elections held concurrently on the
same day. Such elections were held by secret ballot and one could not predetermine the voter turnout
or how voters would vote in each election. None of the parties had agged anything so signicant that
it would have aected the outcome of the presidential election vis á vis the other ve elections held on
that day. There were no unexplained discrepancies between the votes cast for presidential candidates
and other elective positions.
Pursuant to article 138(3)(c) of the Constitution, the power to verify and tally presidential election
results as received at the National Tallying Centre, vested not in the chairperson of IEBC, but in the
Commission itself. The latter carried out the exercise through its secretariat sta, technical personnel,
and any other persons hired for that purpose under the oversight and supervision of the chairperson,
and other members of the Commission.
The chairperson of the IEBC could not arrogate to himself the power to verify and tally the results
of a presidential election, to the exclusion of the other members of the Commission. Under Article
138(10) of the Constitution, although the power to declare the result of a presidential election after
verication and tallying, was vested in the chairperson, he did so only as a delegate of the Commission.
To the extent that regulation 87(3) of the Elections (General) Regulations purported to vest the power
of verifying and tallying presidential election results, as received at the National Tallying Centre, solely
on the chairperson to the exclusion of other members of the Commission, the same was contrary to
and inconsistent with the provisions of the Constitution.
Apart from their eleventh-hour denunciation of the verication and tallying process, and their
averments regarding the conduct of the chairperson, the four Commissioners had not placed before
the court, any information or document showing that the elections were either compromised or that
the result would have substantially diered from that declared by the chairperson of IEBC. They had
not explained why they participated in a verication process when they knew that it was opaque up
until the last minute. The 4 Commissioners acknowledged that the entire election had been managed
eciently and credibly. The chairperson did not make matters any better by maintaining a stoic
kenyalaw.org/caselaw/cases/view/240578/
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