110. In asking the Court not to allow the consolidated Petitions she deposed that public interest will be harmed and allowing it will result in an unconstitutional Parliament necessitating an expensive byelection to reconstitute both Houses fully. It was her case that public interest would be served better by compelling the few remaining political parties to comply. The Submissions: 111. The 3rd – 8th Interested Parties filed written submissions dated 22nd May, 2022. It largely reiterated the deposition in the Replying Affidavit of Ms. Nkonge. 112. It was submitted that both disputes were an abuse of Court process since they have no backing of the law. Court was referred to the decision in the Court of Appeal decision in Muchanga Investments Limited -vs- Safaris Unlimited (Africa) Ltd & 2 Others Civil Appeal No. 25 of 2002 [2009] eKLR. 113. It was submitted that, IEBC, a State organ, is bound to implement the judgment in the Katiba Case because it forms part of the law applicable to the elections. It was stated that “All State organs and State officers must understand that law comprises of the provisions of Constitutions and Acts of Parliament and decisions of superior Courts. The 9th Interested Party’s case: 114. The 9th Interested Party, National Gender and Equality Commission, opposed the consolidated Petitions through the Replying Affidavit of its Chairperson, Dr. Joyce Mwikali Mutinda deposed to on 23rd May, 2022. 115. She deposed that the consolidated Petitions lacked merit and were an abuse of Court process. She stated that they offend the doctrine of res-judicata. 116. She deposed that notice was issued to all political parties through the IEBC’s letter of 27th April 2022 which requested all political parties of the need to comply with the Judgment in the Katiba Case. Judgment – Nairobi High Court Constitutional Petitions No. E211 of 2022 & JR No. E071 OF 2022 Page 21 of 59