discussed the use of technology in elections and made far-reaching recommendations which led, to amongst others, extensive amendments to the Elections Act to provide for use of technology and also technology dedicated regulations, the Elections (Technology) Regulations 2017. [231] These changes, in our view, were meant to re-align several pieces of election-related legislation, with the principles of the Constitution and the electoral jurisprudence that had been developed by the Courts. The cumulative effect of these changes was the establishment of what is now referred to as the Kenya Integrated Election Management System (KIEMS). Henceforth, technology would be deployed to the process of voter registration, voter identification and the transmission of results to the Constituency and National Tallying Centres. [232] Towards this end, Parliament enacted Section 44 of the Elections Act; subsection (1) of which provides that: “there is established an integrated electronic electoral system that enables biometric voter registration, electronic voter identification and electronic transmission of results.” Subsection (3) thereof provides that: “the Commission shall ensure that the technology in use under subsection (1) is simple, accurate, verifiable, secure, accountable and transparent.” [233] Section 39(1C) of the Elections Act then squarely addresses the results transmission aspects of these changes in the law. It provides that: Presidential  Petition  No.  1  of  2017                                                                                                                                                                                                            97  |  P a g e    

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