94 election in Siaya County. Everything was done to depict the petitioner as a candidate who was running against the grain. The elections (sic) were constantly being bombarded with malicious propaganda against him. The propaganda was beyond what was ordinarily expected from opponents in an election campaign. When this was not considered enough, forged posters sprung up late in the campaign showing, falsely, that the petitioner was supporting the Jubilee candidacy, and not ODM or Raila. From the evidence, the County was basically an ODM and Raila zone. I find that the propaganda that the petitioner was supporting Uhuru and Ruto was not only offensive but also a blow below the belt, as it were. Taken together with the election offences as outlined in the foregoing, one cannot say that a fair chance was given to the petitioner to campaign, or that the electors were given a fair chance to pick a candidate of their choice. To put it bluntly, the campaign was not free and fair. The campaign was perverted to the extent that it fundamentally compromised the integrity of the election. 3.8.1.3 It is not an unfair campaign for the leader of a political party to urge voters to elect only candidates vying on the political party’s ticket (Jared Odoyo Okello v IEBC & 3 Others, Kisumu Election Petition No. 1 of 2013). A political party or its leader does not, therefore, breach the Electoral Code of Conduct by urging electors to adopt the so called ‘six-piece’ approach to voting (in the six-piece approach, voters are urged to cast all their ballots for the six elective offices in a general election in favour of one party). Accordingly, courts cannot nullify an election merely because the leader of a political party that enjoys fanatical support in a particular county or constituency urged electors to adopt the ‘six-piece’ approach to voting, even if such a campaign inevitably disadvantages candidates running on the tickets of rival political parties (Jared Odoyo Okello v IEBC & 3 Others, Kisumu Election Petition No. 1 of 2013). 3.8.1.4 Mere boasts, crudities, vulgarities, strong language and exaggerations, typical of political exchanges, do not constitute unfair campaign practices unless they are shown to have undermined the free exercise of the electors’ will (Wavinya Ndeti v IEBC & 4 Others, Nairobi High Court Election Petition No. 4 of 2013). This also applies to promises by an aspirant that the aspirant’s election would lead to development (Wavinya Ndeti v IEBC & 4 Others, Nairobi High Court Election Petition No. 4 of 2013). 3.8.1.5 The exploitation of an electorate’s vulnerability in a manner that makes them so beholden to a candidate as to take away the electorate’s free will, however, may lead to a finding of undue influence and vitiate the election. In Gideon Mwangangi Wambua & Another v IEBC & 2 Others, Mombasa High Court Election Petition No. 4 of 2013, the successful candidate used his private foundation as a channel for giving cheques to needy people and other acts of ‘generosity’. The Court found and held as follows: where a candidate takes advantage of the electorates vulnerability to secure their votes in a manner that makes the electorates beholden to him, that in my view may justify the nullification of the elections results since the results will not be a reflection of the exercise of the free will of the electorates…In this case the Constituency in question is a remote Constituency with high levels of illiteracy, high poverty levels with inadequate infrastructure not to mention lack of adequate water…There was nd overwhelming evidence that the 2 respondent in this case made certain promises to the electorates during his campaign rallies and initiated certain projects. He issued cheques to needy students in the Constituency and this fact was confirmed by his own driver…Whereas the said actions might have been undertaken in his capacity as a director of Mwashetani Foundation, the distinction was clearly lost to the electorates… nd The 2 respondent took a calculated risk in choosing his campaign rallies as the BENCH BOOK ON ELECTORAL DISPUTE RESOLUTION