were not helpful. After citing previous Kenyan case law, the Court summarized its robust response to these insults, noting: “To the Oath of Office we shall remain faithful and defend the Constitution with a view to upholding the dignity and the respect for the Judiciary and the judicial system of Kenya. We shall dispense justice without any fear. We do this to protect the Institution not only for the present but also for the future: Judges serve their term and leave, but the institution of the Judiciary is there to serve today and for posterity.” While the Kenyan judgment shows the benefit of swift and robust post-election judgments, courts must often rule quickly on these issues in the run-up to an election. Various states have developed summary proceedings that provide a framework for courts to adjudicate rapidly on issues that come before them during the election period. However, such swift adjudication processes should not come at the expense of fair administration of justice, complete with a thorough investigation and adequate due process guarantees. Under France’s 2018 false information laws, 50 a summary judge can stop the spread of false information being disseminated online in a “deliberate, artificial or automated and massive manner” during the three-month election campaign period for certain national general elections if the information is “likely to alter … the sincerity of the upcoming election.” 51 In the interest of combatting false information, the oversight body for media content, the French Audiovisual Council (Conseil Supérieur de l’Audiovisuel), also has investigative and administrative sanction powers and can temporarily suspend broadcasting in France (or broadcasting by a television channel controlled or placed under the influence of a foreign State) for the duration of the electoral period. However, these proceedings taking place under extreme deadlines will require adequate resources to ensure the laws can be enforced. In its 2019 decision VIEU et OUZOULIAS v. Twitter International relating to European Parliament elections, the High Instance Tribunal ruled that it could not order Twitter to remove a misleading tweet under France’s false information laws. A government minister tweeted about demonstrators violently assaulting personnel in a public hospital, although it was established that the demonstrators had not engaged in any violence on the premises. The Tribunal found that the minister’s message, although exaggerated, related to actual events; thus, it was not manifestly inaccurate or false. Moreover, there was no proof of artificial or automatic dissemination of the tweet, and news outlets quickly published statements and interviews refuting the violence alleged by the tweet, enabling voters to remain informed. 52 The summary judge ruled on the need for an urgent measure to stop the dissemination of a tweet, but this was not a specialized election judge and they did not act as an arbiter of the fairness of the electoral campaign. While this new civil summary judicial procedure can provide for an effective and quick remedy during a campaign or close to Election Day, critics also questioned its potential misuse, its Electoral Code, Art. L. 163-2-I. (2020) (Fra.). Judges have 48 hours to decide whether to issue an interim order to stop the violation if they choose to do so. 52 Tribunal de Grande Instance de Paris, Référé [Judicial Court of Paris, Emergency Interim Proceedings], May 10, 2019, Vieu et Ouzoulias v. Twitter International, N° RG 19/53935 (Fra.). 50 51 15