Abdalla Mwashetani v. Gideon Mwangangi Wambua & 3 Others68, the Court of Appeal stated that: “Purely from the consequences that flow from the finding that a person is guilty of improper influence, we must conclude that improper influence is serious conduct that has attributes akin to those of an election offence. It is now settled beyond peradventure that the standard of proof where an election offence or such kind of conduct is alleged, is proof beyond balance of probabilities.” [147] In England, however, no such distinction is made. Whether or not allegations of a criminal or quasi-criminal nature are made in a petition, the ordinary civil litigation standard of proof on a ‘balance of probabilities’ applies. This came out clearly in the decision of the Judicial Committee of the Privy Council in Jugnauth v. Ringadoo and Others69 where there was an allegation of bribery. Affirming the decision of the Supreme Court of Mauritius, the Privy Council stated that: “[17]…there is no question of the Court applying any kind of intermediate standard… [19] It follows that the issue for the election Court is whether the petitioner had established, on the balance of probabilities, that the election was affected by bribery in the manner specified in the petition." [148] In many other jurisdictions including ours, where no allegations of a criminal or quasi-criminal nature are made in an election petition, an ‘intermediate standard of proof’, one beyond the ordinary civil litigation Khatib Abdalla Mwashetani v. Gideon Mwangangi Wambua & 3 others, Civil Appeal No. 39 of 2013; [2014] eKLR.   69  Jugnauth v. Ringadoo and Others [2008] UKPC 50.   68 Presidential  Petition  No.  1  of  2017                                                                                                                                                                                                            59  |  P a g e