Independent Electoral and Boundaries Commission shall tally and verify the count and declare the result. [200] The principles cutting across all these Articles include integrity; transparency; accuracy; accountability; impartiality; simplicity; verifiability; security; and efficiency as well as those of a free and fair election which are by secret ballot, free from violence, intimidation, improper influence or corruption, and the conduct of an election by an independent body in transparent, impartial, neutral, efficient, accurate and accountable manner. [201] As we have stated, Section 83 of the Elections Act was not in direct focus in the 2013 Raila Odinga case. That notwithstanding, critics of that decision assert that had this Court disjunctively considered the two limbs of that section arguing that if it had, it would perhaps have reached a different conclusion. Those who support the Court’s observation in that case argue that a holistic interpretation of the section required the conjunctive application and, according to them, that is the interpretation this Court gave the section. What do we now make of these divergent contentions in the light of the pleadings in this petition? [202] Among the well-established cannons of statutory interpretation, is the requirement that in addition to reading the statutes as a whole96, where the words are clear and unambiguous, they must be given their primary, plain, ordinary and natural meaning. The language used must be construed in its natural and ordinary meaning. The sense must be that which the Royal Media Services v. AG, Petition No. 346 of 2012; [2012] eKLR following Olum & Another v. AG of Uganda, [2002] 2 EA 508.   96 Presidential  Petition  No.  1  of  2017                                                                                                                                                                                                            82  |  P a g e    

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