137 Election Petition 1 of 2017). It must be demonstrated that money was given to influence voters or to manipulate them to vote in favour of a candidate (Samwel Kazungu Kambi v Nelly Ilongo and 2 Others, Malindi Election Petition 4 & 5 of 2017; Levi Simiyu Makali v Koyi John Waluke & 2 Others, Bungoma Election Petition 4 of 2017). 4.8.3.3.25 Where electoral violence is alleged, it must widespread, be capable of being traced to the respondents and it must have affected the voting and subsequent election results (Benson Maneno v Jacob Machekele & Others, Malindi Election Petition No. 14 of 2013; Kajembe v Nyange and Others [2008] 2 KLR 1; Lenno Mwambura Mbaga & Another v IEBC & Another, Malindi Election Petition No. 1 & 3 of 2013; Joho v Nyange & Another (No 4) (2008) 3KLR ; Justus Gesito Mugali M’mbaya v IEBC & 2 Others, Kakamega Election Petition No. 6 of 2013; Arthur Papa v Oku Edward Kaunya & 2 Others, Busia High Court Election Petition 2 of 2017; Levi Simiyu Makali v Koyi John Waluke & 2 Others, Bungoma Election Petition 4 of 2017). 4.8.3.3.26 Where the alleged election offence takes the form of a traditional oath, the authenticity of the oath or its compliance with applicable traditional or cultural requirements is irrelevant (Elima v Ohare & Another [2008] 1 KLR (EP) 771). 4.9 Judgments and Reliefs 4.9.1 Section 75(2) of the Elections Act, 2011 empowers the courts to grant ‘appropriate relief’ upon the conclusion of the trial of an election petition. Such relief may include: (i) a declaration of whether the candidate whose election is questioned was validly elected; (ii) a declaration of which candidate was validly elected; or (iii) an order as to whether a fresh election will be held or not. 4.9.2 An election court is required, besides pronouncing judgment, to issue a certificate as to the validity of the impugned election (s 86(1), Elections Act, 2011). The certificate should be forwarded to the speaker of the National Assembly or the Senate in the case of a parliamentary election petition and the Speaker of the relevant County Assembly in the case of a county election petition. 4.9.3 It should be noted that the list of reliefs set out at section 75(2) of the Elections Act is merely illustrative. Election courts usually grant many other reliefs besides those set out in the section, including recount, scrutiny, award of costs and nullification of elections. 4.9.4 An election court may order the IEBC to issue a certificate of election to a candidate if upon a recount the winner is apparent and that winner is not found to have committed an election offence (s 80(4), Elections Act, 2011). The petitioner need not have specifically pleaded or prayed to be declared duly elected for such an order to be issued. In Richard Kalembe Ndile & Another v Patrick Musimba Mweu & 2 Others, Machakos Election Petitions Nos. 1 and 7 of 2013, the Court in para 107 explained the rule as follows: BENCH BOOK ON ELECTORAL DISPUTE RESOLUTION