therefore, important that, while interpreting Section 83 of our Elections Act, this distinction is borne in mind. In the circumstances, authorities from many Commonwealth countries, such as Nigeria, Ghana, Zambia, Tanzania and Uganda whose provisions are not in sync or exact parri materia with ours may not be useful. [194] That is not all. Our present provision is different from that in other countries in two other fundamental aspects. First, the Kenyan Act does not have the word “substantially”, which is in many of the provisions of other countries. Secondly, and fundamentally, in 2011, the Elections Act (No. 24 of 2011) was enacted and repealed the National Assembly and Presidential Elections Act. Section 83 of the new Elections Act, obviously to harmonize it with our Constitution, added that to be valid, the conduct of our elections in our country must comply “with the principles laid down in the Constitution.” This addition was purposive given that the retired Constitution did not contain any constitutional principles relating to elections. In interpreting the Section therefore, this Court must first pay due regard to the meaning and import of the constitutional principles it envisages. [195] Among the well-established cannons of constitutional interpretation is the basic one that the Constitution must be read as an integrated whole. Mr. Justice White, in his dissent (Fuller CJ, McKenna & Day concurring) captured this principle in the case of State of South Dokota v. State of North Carolina95 where he stated: 95 State of South Dokota v. State of North Caroline 192, U. S. 286 (24 S. Ct. 269, 48 L.Ed. 448) Presidential  Petition  No.  1  of  2017                                                                                                                                                                                                            79  |  P a g e    

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