REPUBLIC OF KENYA IN THE HIGH COURT AT CONSTITUTIONAL PETITION NO. OF 2017 IN THE MATTER OF ARTICLE 1, 2, 3, 10, 19, 20, 23, 258 AND 259 OF THE CONSTITUTION OF KENYA 2010. AND IN THE MATTER OF ALLEGED CONTRAVENTION OF FUNDAMENTAL RIGHTS AND FREEDOMS UNDER ARTICLES 1, 27, 38 AND 50 OF THE CONSTITUTION OF KENYA. AND IN THE MATTER OF THE FRESH PRESIDENTIAL ELECTIONS UNDER AND PURSUANT TO ARTICLES 138 AND 140(2) OF THE CONSTITUTION AND IN THE MATTER OF THE FRESH PRESIDENTIAL ELECTIONS SCHEDULED TO BE HELD ON 26 TH OCTOBER, 2017 PURSUANT TO ARTICLE 140 OF THE CONSTITUTION BETWEEN HON. DAVID PKOSING VS NATIONAL SUPPER ALLIANCE ORANGE DEMOCRATIC MOVEMENT WIPER DEMOCRATIC MOVEMENT - KENYA FORD KENYA PARTY AMANI NATIONAL CONGRESS HON. RAILA AMOLO ODINGA HON. STEPHEN KALONZO MUSYOKA HON. WYCLIFFE MUSALIA MUDAVADI HON. MOSES MASIKA WETANGULA INDEPENDENT ELECTORAL & BOUNDARIES COMMISSION (IEBC) WAFULA CHEBUKATI REGISTRAR OF POLITICAL PARTIES THE HON. ATTORNEY GENERAL PETITIONER 1 ST RESPONDENT 3 RD RESPONDENT 3 RD RESPONDENT 4 TH RESPONDENT 5 TH RESPONDENT 6 TH RESPONDENT 7 TH RESPONDENT 8 TH RESPONDENT 9 TH RESPONDENT 10 TH RESPONDENT 11 TH RESPONDENT 12 TH RESPONDENT 13 TH RESPONDENT To: The Honourable High Court of Kenya, Nairobi. PETITION 1
THE HUMBLE PETITION OF HON. DAVID PKOSING, MP WHOSE ADDRESS OF SERVICE FOR THE PURPOSE OF THIS PETITION IS CARE OF KINOTI & KIBE CO. ADVOCATES, QUEENSWAY HOUSE, 5 TH FLOOR, KAUNDA STREET, P.O. BOX 29871-00202, IS AS FOLLOWS. 1 The Petitioner is the current Member of the National Assembly for Pokot South Constituency. 2 The First Respondent National Supper Alliance is a political coalition whose member includes the 2 nd 5 th Respondents herein. Its address of service for purposes of this Petition is GPO, Nairobi. 3 The Second Respondent Orange Democratic Movement is a registered political party within the meaning of Article 91 of the Constitution. Its address of service for purposes of this Petition is care of Orange House, Menelik Road, Kilimani Area, P.O. Box 2478-00202, Nairobi. 4 The Third Respondent Wiper Democratic Movement Kenya is a registered political party within the meaning of Article 91 of the Constitution. Its address of service for purposes of this Petition is care of Chungwa House, Othaya Road, P.O. Box 403-00100, Nairobi. 5 The Fourth Respondent FORD Kenya Party is a registered political party within the meaning of Article 91 of the Constitution. Its address of service for purposes of this Petition is care of Kirkwood House, 2 nd Floor, Kenyatta Market Off Mbagathi Way, Nairobi. 6 The Fifth Respondent Amani National Congress is a registered political party within the meaning of Article 91 of the Constitution. Its address of service for purposes of this Petition is care of Loyangalani, Off James Gichuru Road, Lavington, Nairobi. 7 The Sixth Respondent Raila Amolo Odinga is the party leader of ODM Party and is its presidential candidate during the fresh presidential election scheduled to be held on 26 th October, 2017. His address of service for purposes of this Petition is care of Orange Democratic Movement, Orange House, Menelik Road, Kilimani Area, P.O. Box 2478-00202, Nairobi. 8 The Seventh Respondent Stephen Kalonzo Musyoka is the party leader of the 3 rd Respondent herein. His address of service for purposes of this Petition is care of 2
Wiper Democratic Movement Kenya, Chungwa House, Othaya Road, P.O. Box 403-00100, Nairobi. 9 The Eighth Respondent Moses Masika Wetangula is the party leader of the 4 th Respondent herein. His address of service for purposes of this Petition is care of Kirkwood House, 2 nd Floor, Kenyatta Market Off Mbagathi Way, Nairobi. 10 The Ninth Respondent Wycliffe Musalia Mudavadi is the party leader of the 5 th Respondent herein. His address of service for purposes of this Petition is care of Amani National Congress, Loyangalani, Off James Gichuru Road, Lavington, Nairobi. 11 The Tenth Respondent Independent Electoral and Boundaries Commission is a Constitutional Commission established under Article 88 of the Constitution of Kenya 2010 for purposes of conducting and supervising Elections to any elective office as established under the Constitution. Its address of service for the purposes of this Election Petition shall be under the care of Anniversary Towers, University Way and P.O Box 45371-00100, Nairobi. 12 The Eleventh Respondent Wafula Chebukati - is the Chairman of the Independent Electoral and Boundaries Commission having been appointed as such pursuant to 250 of the Constitution. His address of service for purposes of this Petition is care of Independent Electoral and Boundaries Commission, Anniversary Towers, University Way and P.O Box 45371-00100, Nairobi 13 The Twelveth Respondent the Registrar of Political Parties is the Registrar of Political Parties is the registrar of Political Parties appointed under Section 33 of the Political Parties Act, 2011. Her address of service for purposes of this Petition is care of Lions Place, Karuna Close, Waiyaki Way, Westlands, P.O. Box 1131 00606, Nairobi. 14 The Thirteenth Respondent the Honourable Attorney General is the Legal Representative of the Government of the Republic of Kenya under Article 156 of the Constitution. His address of service for purposes of this Petition is care of Sheria House, Harambee Avenue, P. O. Box 40112-00100, Nairobi. 15 Pursuant to Articles 1, 2, 3, 4 and 10 of the Constitution, Kenya is a constitutional democracy based on the following principles, values and features:- i) Sovereign authority vests in the people of Kenya and it can be directly exercised through elections and referendum. 3
. ii) iii) iv) Every five years on the second Tuesday of August a general election must be held in order for the people to exercise their sovereign power to elect the President, Members of Parliament, Governors, Senators and Members of the County Assemblies. The exercise of the people s sovereign power is conducted and supervised by the Independent Electoral and Boundaries Commission in accordance with the Constitution and national legislation. Political parties are the bedrock of Kenyan democracy and they are bound by Article 91(1)(f) (h) to, inter-alia:- f) respect and promote human rights and fundamental freedoms, and gender equality and equity; g) promote the objects and principles of this Constitution and the rule of law; and h) subscribe to and observe the code of conduct for political parties. v) Further to the above under Article 91(2) of the Constitution Political Parties are prohibited from engaging in or encouraging violence by or intimidation of, its members, supporters, opponents or any other person. vi) The Constitution delegates to the courts the sovereign power of the people to adjudicate over all legal disputes, ensure justice is done to all and to protect and promote the purpose and principles of the Constitution. vii) Under Article 38 of the Constitution Kenyan citizens have a right to make political choices, right to free, fair and regular elections and the right to be a candidate for public office and, if elected, to hold office. 16 Under Article 88 of the Constitution the IEBC is established with responsibility for conducting or supervising referenda and elections to any elective body or office established by the Constitution and any other elections as prescribed by an Act of Parliament. 17 Article 88(5) provides as follows:- The Commission shall exercise its powers and perform its functions in accordance with this Constitution and national legislation. 18 Under Article 82 of the Constitution, Parliament is enjoined to enact legislation to provide, inter-alia, for the conduct of elections and referenda and the regulation and 4
efficient supervision of elections and referenda, including the nomination of candidates for elections. Significantly Article 82(2) requires such legislation to ensure that voting at every election is simple and transparent. 19 Pursuant to Article 82 of the Constitution in August, 2011 Parliament enacted the Elections Act 9No. 24 of 2011) to provide for the conduct of elections to the office of the President, the National Assembly, the Senate County governor and county assembly; to provide for the conduct of referenda, to provide for election dispute resolution and far connected purposes. In April, 2013 the first General Election under the Constitution of Kenya, 2010 was held under the provisions of the Elections Act, 2011. 20 In September, 2016 and January, 2017 the Elections Act, 2011 was substantially amended vide the Elections Laws (Amendment) Act, 2016 and The Elections Laws (Amendment) Act, 2017 to improve the electoral climate and secure better compliance with provisions of the Constitution. 21 The Petitioner avers that in the wake of the decision of the Supreme Court aforementioned the 1 st 9 th Respondents and other leaders of NASA and its affiliate parties have publicly threatened that unless their demands for new electoral framework are met they will either prevent, impede, subvert or otherwise ensure by fair or foul, legal or illegal means that the fresh presidential elections will not be held. 22 Further the Petitioner avers that if the fresh presidential elections aborts by whatever means the Republic of Kenya as likely to plunge into a constitutional crisis on the ground, inter-alia, of legal lacuna on how to conduct new presidential elections thereby necessitating extra-constitutional mechanism to restore the constitutional order. 23 In view of the prohibition in Article 3(2) of the Constitution which outlaws any attempt to establish a government otherwise than in compliance with the Constitution of Kenya, 2010, the Petitioner contends that willful decision and actions by the 1 st 9 th Respondents to impede subvert or otherwise ensure the fresh presidential elections will not be held on 26 th October, 2017 as scheduled amount to a violation of Article 3(2) of the Constitution which constitutes treason within the meaning of Section 40 of the Penal Code. 24 By dint of the obligation of every Kenyan set out in Article 3(1) of the Constitution to respect, uphold and defend it, the Petitioner avers that the 1 st 9 th Respondents are legally bound to promote it and obey the order of the Supreme Court that a fresh election be held within 60 days from 1 st September, 2017 following the invalidation 5
of the presidential elections held on 8 th August, 2017 to be conducted by IEBC subject to their right to seek legal remedy in court. 25 As a consequence of the foregoing the Petitioner states that any willful attempt to boycott or subvert elections in order to trigger a crisis or secure extra-constitutional political advantage shall automatically render the nomination of such party or candidates null and void ab initio. 26 Further to the foregoing, the IEBC Act is one of the independent commissions under Articles 248 of the Constitution and therefore Articles 249(1) and (2) that provides as follows apply: 249. (1) The objects of the commissions and the independent offices are to (a) protect the sovereignty of the people; (b) secure the observance by all State organs of democratic values and principles; and (c) promote constitutionalism. (2) The commissions and the holders of independent offices (a) are subject only to this Constitution and the law; and (b) are independent and not subject to direction or control by any person or authority. 27 The Petitioners aver that on 8 th August, 2017 the second General Election under the 2010 Constitution was held by IEBC under the general legal framework outlined above by the incumbent officers of the IEBC. 28 Pursuant to Article 140 of the Constitution the results of the presidential election were challenged by the presidential candidate of the Orange Democratic Movement the Right Hon. Raila Amolo Odinga and his running mate Hon. Stephen Kalonzo Musyoka. On 1 st September, 2017 a majority of the Supreme Court invalidated the results of the presidential election vide the following orders:- (i) A declaration is hereby issued that the Presidential Election held on 8 th August 2017 was not conducted in accordance with the Constitution and the applicable law rendering the declared result invalid, null and void; (ii) A declaration is hereby issued that the 3 rd Respondent was not validly declared as the President elect and that the declaration is invalid, null and void; (iii) An order is hereby issued directing the 1 st Respondent to organize and conduct a fresh Presidential Election in strict conformity with the Constitution and the applicable 6
election laws within 60 days of this determination under Article 140(3) of the Constitution. (iv) Regarding costs, each party shall bear its own costs. 29 Following the said decision of the Supreme Court leaders of the 2 nd 5 th Respondents who belong to a non-registered political entity known as National Super Alliance (NASA) have launched a campaign to change the legal framework through non-parliamentary methods and to reconstitute the Commission by targeting some of its Commissioners and several members of the Secretariat including its secretary and CEO Mr. Ezra Chiloba. The said Campaign has also sought to secure various legal, administrative and operational reforms before the fresh presidential elections ordered by the Supreme Court is held. The said fresh presidential elections must be held by 31 st October, 2017. 30 Specifically by a public notice titled NASA POSITION PAPER ON IRREDEEMABLE MINIMUM BEFORE THE FRESH ELECTIONS ARE HELD dated September 12, 2017 Hon Musalia Mudavadi, Chair, National Campaign Committee states the reforms that must be implemented before the fresh presidential elections are conducted. In paragraph 10 of the said position paper NASA seeks the removal of the following officials of the IEBC on the purported grounds that they were implicated in wrongdoing by the decision of the Supreme Court of Kenya dated 1 st September, 2017:- 1) Comm. Abdi Guliye 2) Ezra Chiloba (CEO) 3) Marijam Hussein Marijam 4) Betty Nyabuto Deputy Commission Secretary (Operations) 5) James Muhati, Director ICT 6) Immaculate Kassait. 7) Praxedes Tororey 8) Moses Kipkogey 9) Sidney Namulungu 10) Nancy Kariuki 11) Silas Rotich 31 The Petitioner states that in the wake of the decision of the Supreme Court to nullify the presidential election held during the General Election, on 5 th September, 2017 the IEBC published Gazette Notice No. 8751 in a special issue of The Kenya Gazette which, inter-alia, provided that Uhuru Kenya and William Samoei Ruto were the candidate and running mate respectively of the Jubilee Party whereas Raila Odinga 7
and Stephen Kalonzo Musyoka were the candidate and running mate respectively for the ODM Party. 32 In the light of the foregoing the Petitioner states that for purposes of Article 138(2) of the Constitution the fresh presidential elections has been construed to mean a contest for the presidency between Hon. Uhuru Kenyatta of Jubilee Party and his running mate Hon. William Ruto on the one hand and Hon. Raila Odinga of ODM and his running mate Hon. Stephen Kalonzo Musyoka on the other hand. Consequently, in practical terms unless the candidates aforementioned take part in the fresh presidential elections the order of the Supreme Court pursuant to Article 140(3) of the Constitution will not be complied with. 33 Bearing in mind the foregoing the Petitioner states that the threat by the 1 st 9 th Respondents to ensure that the fresh presidential elections will not be held unless Nasa s irreducible minimum reforms are delivered presents the grave spectre of plunging Kenya into a constitutional crisis. The Petitioner avers that the IEBC, the Hon. Attorney General and this Honourable Court are enjoined by law to ensure that the Republic of Kenya does not plunge into a constitutional crisis that will certainly imperil or destroy its political-legal order as a constitutional democracy. The Petitioner is apprehensive that the 1 st 9 th Respondents are likely to resort to unlawful actions and civil disorder to ensure that the fresh presidential elections will not be held as scheduled. This apprehension is aggravated by the fact that the 1 st 9 th Respondent possess the political means and capacity to cause civil disorder in numerous Counties where they command strong political support. These apprehensions are further compounded by the following legal facts. 34 Under Article 138 of the Constitution the procedure of presidential election includes the following elements:- i) If two or more candidates for president are nominated, an election shall be held in each of Kenya s 290 Constituencies. ii) iii) Besides the requirement of receiving more than half of all the votes cast in the election, a successful presidential candidate must receive at least 25 per cent of the votes cast in each of more than half of the Counties. In other words in at least 24 out of the 47 Counties. In declaring the result of the election the chairperson of the IEBC is required by law to indicate the votes cast for each candidate in all the 47 Counties. 35 Taking into account the foregoing, the Appellant is apprehensive that the threats by the 1 st 9 th Respondents to ensure the fresh presidential election will not be held as 8
scheduled may actually materialize in a significant number of Constituencies and Counties thereby putting Kenya s constitutional order into jeopardy. 36 The Petitioner contends that the threatened actions of the 1 st 9 th Respondents are unlawful, subversive and treasonous, inter-alia, on the following grounds:- i) The said threats and actions will violate the rights of over 19 million registered voters under Article 38(3)(b) of the Constitution to vote by secret ballot in any election or referendum without unreasonable restrictions. ii) The impugned actions and threats violate the cardinal principle of free and fair elections which are free from violence, intimidation, improper influence or corruption embodied in Article 81(e) of the Constitution. 37 Under Section 110 of the Elections Act every political party and every person who participates in an election or referendum under the Constitution and this Act shall subscribe to and observe the Electoral Code of Conduct set out in the Second Schedule. As set out in paragraph 3 thereof, the object of the Code is to promote conditions conducive to the conduct of free and fair elections and a climate of tolerance in which political activity may take place without fear, coercion, intimidation or reprisals, Paragraph 4 of the Code fortifies the objectives as follows:- All registered political parties and other persons bound by this Code shall endeavour to promote the object of the code to enable free political campaigning and open public debate to take place in all parts of Kenya during an election period 38 Under paragraph 6(k) of the Code all those bound by it shall, throughout an election period in relation to the Commission ensure, inter-alia, that they acknowledge the authority of the Commission in the conduct of the election or referendum and implement the orders and directions of the Commission. Equally notable paragraph 6(l) to (o) provides that those bound by the Code shall - (l) reassure voters with regard to the impartiality of the Commission and the secrecy and integrity of the ballot, and to reaffirm that no one should know how any other person has voted; (m) take reasonable steps to discipline and restrain their party office-bearers, employees, candidates, members and persons who support the political party who (i) infringe this Code; 9
(ii) engage in activities of commission or omission which constitute offences under the electoral laws or otherwise fail to observe this Code; and (iii) contravene or fail to comply with any provision of the electoral laws; (n) agree for party office bearers, employees, candidates members and persons who support the political party to submit to the disciplinary procedures of the Commission for any violation of this Code; and (o) without prejudice to the right to present a petition to an election court, accept the final outcome of the election and the Commission s declaration and certification of the results thereof. 39 The foregoing provisions are underscored by the Code of Conduct for Political Parties made pursuant to Articles 91 and 92 of the Constitution and Section 8 of the Political Parties Act, 2011 to regulate the behavior of members and office holders of the political parties, aspiring candidates, candidates and their supporters to promote good governance and eradicate political malpractises. Importantly para 6(a), (b) and (e) of the said Code provides that every political party shall - (a) respect, uphold and defend the Constitution of Kenya; (b) respect and uphold this Act and any other written law relating to elections and political parties; (e) respect, uphold and promote human rights and the rule of law; 40 The demands contained in the NASA position paper dated 12 th September, 2012 constitute an attempt to establish a government of Kenya otherwise than in compliance with the Constitution of Kenya, 2010 which is prohibited by Article 3 thereof. 41 It is important for this Honourable Court to uphold the Rule of Law and prevent the spectre of a constitutional crisis in Kenya by ensuring that the fresh presidential elections are conducted in strict conformity with the Constitution and applicable laws of Kenya to conduct the fresh presidential elections. YOUR PETITIONER THEREFORE HUMBLY PRAYS THAT: a) THAT a declaration be issued to declare that pursuant to Article 140(3) of the Constitution and the 10 th Respondent s Gazette Notice No. 8751 dated 5 th 10
September, 2017 the candidates nominated to contest the fresh presidential election are bound by the order of the Supreme Court of Kenya made on 1 st September, 2017 to participate in the said election. b) THAT a declaration be issued to declare that any decision, action or omission by the 6 th and 7 th Respondents by themselves and their supporters or jointly with the 1 st - 5 th and 8 th - 9 th Respondents to boycott, subvert, impede, cause or otherwise ensure that the fresh presidential election scheduled to be held on 26 th October, 2017 is not conducted is unlawful by dint of Articles 3, 38 and 140 (3) of the Constitution read with IEBC s Gazette Notice No. 8751 dated 5 th September, 2017 and treasonous within the meaning of Section 40 of the Penal Code Cap 63 Laws of Kenya. c) THAT a declaration be issued to declare that any decision, attempts, threats, actions or omissions by the 2 nd, 6 th and 7 th Respondents namely ODM Party, Hon. Raila Amolo Odinga and Hon. Stephen Kalonzo Musyoka to boycott, subvert, impede, cause or otherwise ensure that the fresh presidential election scheduled to be held on 26 th October, 2017 is not conducted amounts to contempt of the orders of the Supreme Court of Kenya made on 1 st September, 2017. d) THAT a declaration be issued to declare that under Articles 138 and 140(3) of the Constitution any decisions, actions or omissions by the 1 st - 9 th Respondents calculated or intended to and/or causing the boycott, subversion or failure to conduct the fresh presidential election on 26 th October, 2017 in all or some of Kenya s 290 Constituencies and 47 Counties shall not negate, affect or otherwise compromise the validity of the fresh presidential elections. e) THAT a declaration be issued to declare that any decision, action or omission by the 6 th and 7 th Respondents to boycott, subvert or otherwise ensure the fresh presidential election will not be conducted on 26 th October, 2017 pursuant to Article 140(3) of the Constitution and the orders of the Supreme Court of Kenya made on 1 st September, 2017 constitute illegality and treason within the meaning of Articles 3, 38 and 138 (2) of the Constitution and section 40 of the Penal Code and shall automatically render the nomination of the 6 th and 7 th Respondents under the 10 th Respondents Gazette Notice No. 8751 dated 5 th September, 2017 null and void ab initio. f) THAT on account of the 2 nd, 6 th and 7 th Respondents contempt of the Order of the Supreme Court of Kenya made on 1 st September, 2017 and violation of Articles 3, 138 and 140 of the Constitution, an order of certiorari be issued to quash the 10 th Respondent s Gazette Notice No. 8751 dated 5 th September, 2017 to the extent that it specifies that Hon. Raila Amollo Odinga and Hon. Stephen 11
Kalonzo Musyoka are presidential and running mate candidates in the fresh presidential election scheduled to be held on 26 th October, 2017 as ordered by the Supreme Court of Kenya pursuant to Article 140(3) of the Constitution. g) THAT a declaration be issued to declare that the 10 th Respondent - the Independent Electoral and Boundaries Commission - is enjoined to determine at the close of the campaign period for the fresh presidential election scheduled for 26 th October, 2017 whether the two nominated candidates under Gazette Notice No. 8751 dated 5 th September, 2017 have abandoned their respective quest for the seat of president and act accordingly under Article 138 of the Constitution. h) THAT an order of mandatory injunction be issued to compel the 10 th Respondent - the Independent Electoral and Boundaries Commission - to determine at the end of the campaign period for the fresh presidential election scheduled to be held on 26 th October, 2017 whether the 6 th and 7 th respondents have repudiated, renounced or otherwise withdrawn their nomination under Gazette Notice No. 8751 dated 5 th September, 2017 and act accordingly under Article 138 of the Constitution. i) THAT a declaration be issued to declare that upon the 10 th Respondent - the Independent Electoral and Boundaries Commission - determining that the 6 th and 7 th Respondents have renounced, repudiated, withdrawn or otherwise abandoned their nomination under Gazette Notice No. 8751 dated 5 th September, 2017 the fresh presidential election scheduled to be held on 26 th October, 2017 shall not be held and Hon. Uhuru Muigai Kenyatta shall be declared as having been elected President pursuant to Article 138(1) of the Constitution. j) THAT a declaration be issued to declare that the Petitioner s political rights protected by Articles 27, 38, 138 and 140(3) of the Constitution have been violated by the political scheme by the 1 st 9 th Respondents to subvert, boycott, impede or otherwise ensure the fresh presidential election ordered by the Supreme Court of Kenya pursuant to Article 140 (3) of the Constitution is not held as scheduled on 26 th October, 2017. k) THAT an order of mandatory injunction be issued to compel the Registrar of Political Parties to deregister the 1 st 5 th Respondents herein under Section 21 of the Political Parties Act, 2011 on account of violation of Article 91 of the Constitution in relation to the fresh presidential elections scheduled to be conducted by IEBC by 30 th October, 2017. l) THAT the Costs of this Petition be borne by the Respondents in any event. 12
DATED at Nairobi this day of 2017 KINOTI & KIBE COMPANY ADVOCATES FOR THE PETITIONER DRAWN & FILED BY: KINOTI & KIBE CO. ADVOCATES QUEENSWAY HOUSE, 5 TH FLOOR KAUNDA STREET P.O. BOX 29871 TO BE SERVED UPON: NATIONAL SUPPER ALLIANCE ORANGE DEMOCRATIC MOVEMENT ORANGE HOUSE MENELIK ROAD KILIMANI AREA P.O. BOX 2478-00202 WIPER DEMOCRATIC MOVEMENT - KENYA CHUNGWA HOUSE OTHAYA ROAD P.O. BOX 403-00100 FORD KENYA PARTY KIRKWOOD HOUSE, 2ND FLOOR KENYATTA MARKET OFF MBAGATHI WAY AMANI NATIONAL CONGRESS LOYANGALANI, OFF JAMES GICHURU ROAD LAVINGTON, 13
HON. RAILA AMOLO ODINGA C/O ORANGE DEMOCRATIC MOVEMENT ORANGE HOUSE MENELIK ROAD KILIMANI AREA P.O. BOX 2478-00202 HON. KALONZO MUSYOKA C/O WIPER DEMOCRATIC MOVEMENT - KENYA CHUNGWA HOUSE OTHAYA ROAD P.O. BOX 403-00100 HON. MOSES WETANGULA C/O FORD KENYA PARTY KIRKWOOD HOUSE, 2ND FLOOR KENYATTA MARKET OFF MBAGATHI WAY HON. WYCLIFFE MUSALIA MUDAVADI AMANI NATIONAL CONGRESS LOYANGALANI, OFF JAMES GICHURU ROAD LAVINGTON, INDEPENDENT ELECTORAL & BOUNDARIES COMMISSION ANNIVERSARY TOWERS, 7 TH FLOOR UNIVERSITY WAY WAFULA CHEBUKATI C/O INDEPENDENT ELECTORAL & BOUNDARIES COMMISSION ANNIVERSARY TOWERS, 7 TH FLOOR UNIVERSITY WAY REGISTRAR OF POLITICAL PARTIES LIONS PLACE, KARUNA CLOSE WAIYAKI WAY, WESTLANDS P.O. BOX 1131-00606 14
THE HON ATTORNEY GENERAL ATTORNEY GENERAL S CHAMBERS STATE LAW OFFICE SHERIA HOUSE 15