ordered for the scrutiny of all Forms 34 and 36 in the 2013 Raila Odinga case. (ii) The Law Society of Kenya [120] The Law Society of Kenya (LSK) was admitted as the 2nd amicus curiae and limited by the Court to make submissions in regard to the interpretation of Section 83 of the Elections Act. Teaming up with Mr. Ombati, Mr. Mwenesi, learned counsel for the LSK, emphasized the centrality of a voter in a democratic form of government and urged that in interpreting the meaning and scope of Section 83, this Court should consider its history and Constitutionality as well as its interpretation in the 2013 Raila Odinga case. The history of Section 83 was thus traced to Section 28 of the National Assembly and Presidential Elections Act (repealed) all the way to the English Ballot Act 1872. Reference was also made to the decision in Morgan v. Simpson39 where the Court stated that an election conducted substantially in accordance with the law will not be invalidated by a breach of the rules or a mistake at the polls which did not affect the result. [121] The Society urged that Section 83 was not straightforward and had posed difficulties in judicial interpretation as to what constitutes an administrative irregularity which can invalidate an election. It was submitted that in interpreting Section 83 of the Elections Act in the 2013 Raila Odinga case, this Court laid out a broad test: whether an alleged breach of law negates or distorts the expression of the people’s electoral intent. It was contended in that regard that, from the Court’s interpretation, 39 Morgan v. Simpson (1974) 3 All ER 722. Presidential  Petition  No.  1  of  2017                                                                                                                                                                                                            48  |  P a g e