UNIVERSITY OF NAIROBI

ADMINISTRATIVE LAW

GROUP 7 WRITE-UP 2018

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NAMES REGISTRATION SIGNATURES
NUMBERS

Arori Isaac Rabbin G34/3260/2017

Mwanahamisi Adam G34/46571/2017

Mwangi Emma Wahito G34/3304/2017

Kariuki Jane Wambui G34/3250/2017

Justice Okumu G34/45783/2017

David Irungu Kimani G34/3207/2017

Gekonge Edwin Mariga G34/3262/2017

Brian Mosobera G34/3225/2017

Ndungu Kevin Mungai G34/3397/2017

Asiago Bosibori Margit G34/3375/2017

Muya John Ngirachu G34/3382/2017

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Table of Contents

HISTORICAL DEVELOPMENTS OF JUDICIAL REVIEW IN KENYA...................................2

THE 1956-1992 PHASE..............................................................................................................2

THE 1992 – 1996 PROCEDURAL CHANGES.........................................................................3

THE 1996 – 2009 PROCEDURAL CHANGES.........................................................................4

THE POST 2010 PHASE (NEW CONSTITUTIONAL DISPENSATION)..............................5

DISTINGUISHING JUDICIAL REVIEW AND ORDINARY REVIEW.....................................6

Grounds for Review.....................................................................................................................7

Grounds for Judicial Review........................................................................................................7

PROCEDURE FOR APPLICATION OF REVIEW...................................................................7

PROCEDURE FOR APPLICATION OF JUDICIAL REVIEW................................................8

REFORMS AND REMEDIES AS TO JUDICIAL REVIEW..................................................11

DISTINGUISHING JUDICIAL REVIEW AND STATUTORY APPEAL.................................13

PROCEDURE OF MAKING STATUTORY APPEAL...........................................................14

REMEDIES OF STATUTORY APPEALS..............................................................................15

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4
HISTORICAL DEVELOPMENTS OF JUDICIAL REVIEW IN KENYA

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THE 1956-1992 PHASE

Judicial review law in Kenya borrows heavily from England. The orders of mandamus, certiorari
and prohibition were previously known as Prerogative writs and were issued in the name of the
King or Queen to exercise control over inferior bodies and tribunals. With the onset of separation
of powers the United Kingdom the courts took up the role of exercising judicial powers. The
United Kingdom Parliament passed the Administration of Justice Act in 1938 that is the basis of
the Law Reform ordinance,1956 imported to Kenya by virtue of section 8 (2) and provides that:-

“ In any case which the high court of England is by virtue of section 7 of the
Administration of Justice Act, 1938 of the United Kingdom empowered to make an order of
mandamus, prohibition or certiorari the Supreme Court shall have the power to make a like
order. Provided that no order of mandamus, prohibition or certiorari shall be made in any case
in which the Supreme Court is empowered by the exercise of the power of review or the criminal
procedure code to make an order having the like effect as the order applied for would be
rendered unnecessary”1.

This provision ensured that the High Court of Kenya had the power to make statutory orders in
any case in which the prerogative writs could formerly issue in England replacing writs with
orders. Another development took place in 1960 and in this year section 8 (2) of the 1956
Ordinance which had until then restricted applications for these orders only to cases where there
were no alternative remedies was replaced. This section was replaced by another ordinance
known as the Law Reform Ordinance No. 16 of 1960. Later in 1966, to reflect the independence
of Kenya from the crown of England, the word “crown” then present in a number of provisions
of statutes in Kenya was changed to “government”. Regardless of these changes, the Law reform
act which was inherited from the Law Reform Ordinance of 1960 still recognized English Law
governing the prerogative orders. For the next two and a half decades, due to the prevailing
circumstances characterized by lack of Judicial independence and credibility not much
developed in as far as judicial review in Kenya. The nineties were a tumultuous period for
Judicial review as various changes, primarily procedural, were enacted
1
Law reform ordinance of 1956, sec 8(2)

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THE 1992 – 1996 PROCEDURAL CHANGES

The Rules Committee, on 9th June 1992, enacted the legal notice No. 164 of the 1992 while
performing their mandate in keeping the rules governing court practice in constant review.2This
had a great impact on the Judicial Review procedure here in Kenya.

First, it deleted the title order LIII which read, ‘Orders of Mandamus, Prohibition, Certiorari’ and
substituted with ‘Application for Judicial Review’. This was to allow general application 3 in
which the applicant needed not to specify the order sought since the court in its discretion would
allow any remedies or contributions thereof it deemed fit4.

Secondly, under section 2 (b), it repealed rules 1 and 2 of the civil Procedure rules which had
made leave a mandatory requirement in the application of the Judicial Review. This had the
effect of hearing the matter at once at the substantive application.

Section 2 also conferred discretion on the high Court to extend the time in which the application
is to be made. By stating that the judicial review shall be made promptly and in any event 6
months from the date when rounds for the applicants arose unless the high court considers there
is a good reason for extending the period within which the application shall be made. This was
declared a nullity in Raila Odinga and 6 Others V Nairobi City Council 5 for seeking to override
the Law Reform Act sine a subsidiary legislation cannot enact an act of parliament. The
Subsidiary legislation ought to promote the intention of the Act of Parliament and not to go way
beyond it.

Thirdly, it deleted rule 1 of Order 53 which made a mandatory requirement for the applicant to
give notice for leave not later than the preceding day to the registrar. This, by implication, also
deleted Rule 1 (4) which allowed grant for leave to operate as stay of the proceedings until
determination or ordered otherwise6. However, as the legal notice removed the requirement for

2
PLO Lumumba and Peter Kaluma, Judicial Review( Law Procedure and Practice 2 nd edn Law Africa 2012)
3
Peter Kaluma, Judicial Review (Law Procedure and Practice 2 nd edn Law Africa 2012)
4
National Democratic Union V Attorney General Misc. Application 145 of 1992
5
Misc. Application No. 899 of 1993
6
Mwangaza Trust Misc. Application no. 98 of 1995

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leave, it neglected to delete rules 3 and 4(1) of order 53 of the civil procedure rules which
required a copy of statement accompanying application for leave to be served with the notice of
motion of the affected parties.

The Court, in 1993, was availed an opportunity to scrutinize the legality of the legal notice
particularly the deletion of the requirement for leave before applying for the prerogative orders.
The court held that rules made pursuant to a statute are subsidiary legislation. They are made
under delegated power. A delegate’s power is confined to the objective of the legislature. The
main reason of delegation is that the legislature itself cannot go into sufficient detail so it makes
a skeleton act. The delegate supplies the meat thus the intention of the legislature must always be
prime guide to the meaning of the delegated legislation. Thus the deletion for the requirement of
leave no longer existed for want of jurisdiction on the part of the Rules Committee.7

It also made competent for one judge to determine a Judicial Review application and not by 2 as
was earlier.

THE 1996 – 2009 PROCEDURAL CHANGES

The 1996 phase of the history of Judicial Review was marked by the restoration of the
requirement of leave before applying for judicial review and court jurisdiction’s to order leave to
operate to stay the decision, the subject matter of judicial review proceedings. 8 This was brought
forth after the promulgation of the Civil Procedure (Amendment) Rules by the Rules Committee.

Clarity of the law being core, the Chief Justice (then Evans Gicheru) later issued practice
directions in 2003, to provide guidance on dealing with matters judicial review. The directions
denoted:

7
Kenneth Stanley Matiba V Attorney General Misc. Application no. 790 of 1993
8
Peter Kaluma, Judicial Review: (Law Procedure and Practice 2nd edn Law Africa 2012)

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 a) Establishment of a division of the High Court to deal with Judicial Review and
constitutional applications.9 This step re-organized information and the materials on
Judicial Review which were scanty before. As a progress in Jurisprudence, the concept
Judicial Review started being a major subject in the country.
b) Nomination of three judges of the High Court to preside over public law matters in
Nairobi.10

The new court division propounded the re-birth of the significance of the principles of
administrative law (e.g. proportionality, legitimate expectation etc.) as independent foundations
of review.

Further practice directions were issued on 19th January 2007 under Legal Notice No. 300 of 2007
directing the filing of the Judicial Review proceedings. It provided that they “must be filed at the
Central Office Registry of the High Court in Nairobi except where the leave of the Chief Justice
is obtained for filing in any District Registry.”11

The above directives elucidated uproar especially from Law Society of Kenya which did apply to
have them quashed and petitioned to the President, His Excellency Emilio Mwai Kibaki, “to
establish a tribunal to preside over the removal of the Chief Justice on grounds that he had
limited access to justice in this important area of law and unlawfully curtailed the jurisdiction of
High Court judges presiding over courts outside Nairobi to hear and determine Judicial Review
applications, through the gazette notice.”12

The Chief Justice, on 27th February 2009, through Legal Notice No. 1756 of 2009 quashed Legal
Notice No. 300 of 2007. The same directed “there be a special register for judicial review and
constitutional applications in appropriate High Court registries and that they be heard on a
priority basis and without delay.”13

9
Peter Kaluma, Judicial Review: (Law Procedure and Practice 2nd edn Law Africa 2012)
10
Ibid.
11
Peter Kaluma, Judicial Review: (Law Procedure and Practice 2nd edn LawAfrica 2012)
12
Ibid.
13
Peter Kaluma, Judicial Review: (Law Procedure and Practice 2nd edn LawAfrica 2012)67

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THE POST 2010 PHASE (NEW CONSTITUTIONAL DISPENSATION)

The promulgation of the constitution of Kenya 2010 brought about significant changes with
regards to judicial review in Kenya. Many statutes and rules as well as common law principles
have been declared invalid as they are contrary to the values and principles of the constitution.
The constitution of Kenya 2010 is not preservative but rather transformative. It seeks not to
preserve the past which is characterized by strife, pain and injustices and judicial positivism. An
area of great concern is one that involves fair administrative action. This is no longer relegated to
statutory or common law sphere but derives its life from the constitution. The Fair administrative
actions act 2015 served to emphasize provisions of article 47 of the constitution. A court can
review an administrative action or decision based on the grounds of reasonableness, rationality
and proportionality14 this presents a significant shift on the approach to Judicial review in Kenya.
The Fair administrative actions act, 2015 has revised the principles that guide judicial review in
Kenya by allowing judicial review on the basis of merits of a decision. Public officers are now
duty bound by law to observe the values, spirit and tenor of the constitution of Kenya 2010.

“..Sometimes a change in the law precedes societal change and is even intended to stimulate it.” 15
The shift to this new model of judicial review requires the understanding and cooperation of all
the members of the legal profession as there seems to be a huge resistance from those
indoctrinated with common law principles.16

DISTINGUISHING JUDICIAL REVIEW AND ORDINARY REVIEW

Judicial review according to black’s law dictionary is a court’s power to review the action of
other branches or levels of government especially the courts power to invalidate legislative and
14
Fair administrative action act 2015
15
Aharon Barak, The judge in a democracy
16
Republic vs Public Procurement Administrative Review board & 2others,Ex parte seven seas Tech and
Kevin k. Mwiti & others vs Kenya school of Law & 2 others

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executive actions as being unconstitutional. Ordinary review is consideration, inspection or
reexamination of a subject or thing.17 It is simply a second look at a decision already made by the
authority which made it,

Grounds for Review

Any person aggrieved by decree or an order may apply for a review on the following conditions.

 Discovery of new and important matter of evidence which after the exercise of due
diligence which was not within the knowledge of the applicant or could not be produced
at the time the decision in question was made.
 Mistake or error apparent on the face of the record.
 Any other sufficient reason

Grounds for Judicial Review

The courts have developed certain norms to secure lawful exercise of power, these norms form
the grounds of judicial review and currently include18:

 Ultra vires
 Abuse of power
 Irrelevant considerations
 Unreasonableness
 Bad faith
 Error of law on the face of records
 Proportionality
 Legitimate expectations
 Fairness and natural justice

17
Blacks law dictionary 8th edition
18
Peter Kaluma Judicial Review: Law procedure and practice 2 nd edition

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PROCEDURE FOR APPLICATION OF REVIEW

An application for review should be made to the very judge who passed or made the order. If the
judge is no longer available it should be heard by the successor to that office.

PROCEDURE OF THE HEARING

Application for review may be divided into 3 stages19.

 An application for review begins ordinarily with an ex parte application by the aggrieved
party.
 In the 2nd stage, the application for review shall be heard inter parties by the same court
that posted the decree.
 In the 3rd stage, the matter will be heard on the merits usually the court will hear it at
once or may fix a hearing for a later date.

PROCEDURE FOR APPLICATION OF JUDICIAL REVIEW

Application is made by way of chamber summons and is to be accompanied by a statement

setting out the name and description of the applicant, the relief sought and the ground on which
the relief the sought and support affidavit(s) setting out the facts and evidence relied upon.20

Notice for application for leave is given to the registrar of the High Court. Time limitation is
important. Order 53 provides for time limitation within which a person can apply for leave.
Application for certiorari must be made within 6 months from the date the cause of action was
decried. Time limitation is not stipulated for mandamus and prohibition but it is required that an
application is filed within reasonable time.

19
www.kenyalawresourcescentre.org>review

20
Order LIII,rule1(2) civil procedure rules

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The grant of leave will operate as a stay of proceedings where you are seeking to quash whatever
has taken place under certiorari. Stay will only apply in the case of certiorari and prohibition and
not mandamus.21

Once the application for leave has been granted, an application by way of notice of motion is
made which is made within 21 days of the grant of leave. If personal allegations have been made
you must serve the party that allegations have been made against.

Copies of the statement accompanying the application for leave must be served together with the
motion and copies of affidavits used in the application for leave. 22The affidavit of service is filed
within 8 clear days of hearing. Lastly, the hearing where the application for judicial review is
done.

Distinction between Judicial Review and Ordinary Review

Distinction is found on the functional and operational values, tribunals which exercise such
jurisdiction and their derivative plus constitutional foundations. Both judicial review and
ordinary review have been clearly an precisely defined before in this essay. It is evident from
those definitions that the major distinction of the two terminologies actually comes from their
description.

Judicial review being judicial control of powers, functions and procedures of administrative
authorities while ordinary review also called review being relooking the judgment of a court of
law. Despite this distinction it is quite clear that both involve finding redress for aggrieved
parties in courts of law.23 Both of these modes see to it that individuals who feel that decisions
that have been made by various administrative agencies as well as judicial bodies, are not
satisfactory, get an avenue of addressing them.

One can only apply for judicial review in the High Courts and not the magistrates Courts. 24 This
is due to the special jurisdiction that is vested in the High Court of Kenya as the ultimate
guarantor of legality to scrutinize actions and decisions of administrative officers and institutions

21
https://ogekazacharia.blogspot.com/2017/04/judicial-review-explained-kenya-law.html

22
Peter kaluma Judicial review: Law Procedure and Practice 2 nd edition
23
PLO Lumumba & PO Kaluma, Judicial Review Of Administrative Actions in Kenya; pg 1
24
Law Reform Act, pg 58

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to ensure that their powers are exercised within relevant legal boundaries. 25 This is to prevent
maladministration and organizational injustice within administrative agencies.

There are various statutory provisions on these two forms of reviews. Judicial Review is
provided for under Order 53 of Civil Procedure Rules while Ordinary Review is provided for
under Order 44 of the same Act. An additional act that touches on these reviews is the Law
Reform Act. The Fair Administrative Action Act of 2015 under section 7also substantively
provides for judicial review and the grounds for which one can institute such proceedings before
a court of law.

There is no time limitation to when one can apply for an ordinary review. However it is advised
that this should not be deemed to be an opening to intentionally stall and delay matters. That is
why the relevant provisions proceed by stating that despite having no specific time limit,
applications should be done without unreasonable delay. The same does not apply for judicial
review. The time limit for judicial review and most specifically, order of certiorari is 6 months
while for mandamus and prohibition the provisions are silent.26

It is quite interesting to note also that another distinction between these two reviews is that there
is no requirement of leave of court to apply while under judicial review it is mandatory that one
has to seek leave of court.

The grounds for these various review also differ just as is clearly stipulated below. Judicial
review is concerned with the decision making process and the decisions are taken before a
different tribunal often higher in hierarchy for determination while ordinary review involves a
tribunal revisiting its own decision.27 It is quite different with ordinary review where the similar
judge has the discretion of relooking his previous decision.

In both, a person seeking review of a decision must justify the allegation of discovery of a new
matter or evidence which was not within his knowledge or could not be adduced by him when
decision was made. The allegations have to be proved in order for a court of low to be able to
take appropriate action.

25
PLO Lumumba & PO Kaluma, Judicial Review of Administrative Actions in Kenya, pg 21
26
Civil Procedure Act, order 53 rule 2
27
Okiya Omtatah v Communication Authority of Kenya & 8 Others (2018) e KLR

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Remedies for both review are very much different as will be observed below. Judicial review is
not an appeal from a decision but a review of the manner in which a decision was made. 28
Professor Wade clearly puts it that “while an appeal the question is right or wrong? On review,
the question is whether the process was lawful or unlawful?”

The final distinction between the two reviews is that an ordinary review grants the opportunity to
reconsider its own decision while judicial review is inherent and is concerned with only the
legality of administrative actions.

REFORMS AND REMEDIES AS TO JUDICIAL REVIEW

Reforms.

Judicial review has gone a great mile in defense against administrative injustice, oppression and
arbitrariness. “Judicial review is the courts’ way of enforcing the rule of law; ensuring that public
authorities’ functions are undertaken according to the law (constraint) and they are accountable
to the law. Ensuring, in other words, that public bodies are not above the law.”29

Judicial review has undergone several changes and reforms since its conception in Kenya, on
onset of the Law Reform Ordinance No. 48 of 1956. These changes can be attributed to the fact
that the administrative system in Kenya and globally as a whole gradually undergoes changes
from time to time in the modern day historical setting.

Prior to the Promulgation of the New Constitution 30, judicial review in Kenya was facilitated by
two legislations. These are: Section 8 and 9 of the Law Reform Act (Substantive) and Order 53
of the Civil Procedure Rules (Procedural).

The constitution, in Article 47 gives every person a right to fair administrative action that is
expeditious, efficient, lawful, reasonable and procedurally fair. 31 This was a great mile stone and
revolution in promoting judicial review and offer remedy to aggravated citizens. The

28
North Wales Police v Evans (1982) 1 WLR, by Lord Brightman
29
Michael Fordham, Judicial Review Handbook, 2012 Edn.
30
Constitution of Kenya, 2010.
31
Constitution of Kenya 2010 Art 47 (1)

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revolutionary constitution has also vested judicial review powers on the High Court of Kenya
under Article 165 of the constitution. The Fair Administrative Action Act, 2015, has also been a
great reform to the judicial review process in Kenya. It outlines the judicial review institutions 32,
period for determination of applications and appeals33, and procedures for judicial review.34

However, there needs to be more reforms in judicial review. One such reform is the introduction
of Epistolary Jurisdiction. This involves writing a letter to any judge seeking enforcement of
certain issues or seeking redress on rights infringement by administrators. It will help make
judicial review process quick, cheap and accessible to every person. The legal processes should
also be streamlined since the current system is too slow.

Remedies.

The courts/ tribunals give several remedies as to judicial review in execution of the orders of
certiorari, prohibition, mandamus and declarations/injunctions.

Restraint- the courts/ tribunals may restrain the involved administrator from continuing to act in
a manner which breaches their duty, or infringes the rights of the concerned parties.

Explanatories- they may direct the administrator to give reasons for the administrative action or
decision they took as per the matter in hand.

Prohibition- they may also prohibit the concerned administrator from acting in a certain manner
or from making a certain decision.

Scrapping- they may also direct the action, decision or legislation by the administrator to be set
aside or scrapped, and may also direct for further insight on the decision by the administrator,
and until such further consideration, such decision/action is suspended.

Relief- they may also give the aggrieved party a temporary relief.

Compensation for damages- they may also award for costs or damages incurred.

32
Fair Administrative Action Act 2015, S7
33
Fair Administrative Action Act 2015, S8
34
Fair Administrative Action Act 2015, S9

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DISTINGUISHING JUDICIAL REVIEW AND STATUTORY APPEAL

Statutory appeal commonly referred to as an appeal in civil practice is the complaint to a

superior court of an injustice done or error committed by an inferior one, whose judgment or
decision the court above is called upon to correct or reverse. 35 A statutory appeal can only be
made from an inferior court to a superior court and the court is concerned with the merit of the
decision made in the inferior court. Judicial review is one court’s review of another court’s
proceedings and judgments typically, a higher court review of a lower court. It can also be a
review of an administrative body’s factual or legal findings36.

In judicial review courts are concerned with either a judgement from a court or decision made by
an administrative body in the exercise of its functions is lawful or unlawful. In statutory appeal
the higher court is concerned whether the trial court’s decision is either right or wrong on the
basis of merit.

In Joseph Waweru Kaniaru v Republic 37 , the appellant filed an appeal to the chief magistrate
court of a conviction of defilement and an imprisonment sentence of 25 years which is above the
mandatory minimum requirement of 20 years. In the trial court of the senior resident magistrate,
the appellant had pleaded not guilty .The chief magistrate court heard the case for with proper
visit to the evidences used in the conviction of the appellant. The fact that concrete evidence
existed to prove the appellant guilty and no new evidence was available whatsoever to prove
erroneous of merit of the decision that was earlier given, the appellate court confirmed his
conviction but reduced the sentence to the mandatory 20 years imprisonment. Professor John
Wade once said that, on appeal, the question is right or wrong? On review the question is lawful
or unlawful? In this case, the convict the appellant was right but to give him a sentence above the
mandatory minimum requirement of the crime was a wrong conclusion of the law on the basis of
merit and thus a good ground for appeal.

Right to appeal is a statutory right that must be conferred from the statute .If a person feels
aggrieved by a court decision, they have a constitutional right to appeal. If convicted, to appeal
35
Black’s Law Dictionary 2nd edition.
36
Black’s Law Dictionary 2nd edition.
37
Joseph Wawe Kaniaru v Republic [2016]

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to, or apply for review by, a higher court as prescribed by law 38.The supreme court has an
appellate jurisdiction to hear cases from the court of appeal and any other tribunal as prescribed
by the national legislation .The statutory right to appeal in the supreme court is any case
involving the interpretation or application of this Constitution; and in any other case in which the
Supreme Court, or the Court of Appeal, certifies that a matter of general public importance is
involved39.The court of appeal has a jurisdiction to hear appeals from the high court and any
other court or tribunal prescribed by an act of parliament 40.The high court has unlimited
jurisdiction in both criminal and civil matters to hear an appeal from a decision of a tribunal
appointed under this Constitution to consider the removal of a person from office, other than a
tribunal appointed under article 14441 .

A statutory appeal can be taken to the higher court within a reasonable time whereas judicial
review is to be taken to court within six years from the day the decision was made.

PROCEDURE OF MAKING STATUTORY APPEAL.

Appeals are filed through a memorandum of appeal from the subordinate courts to the appellant
courts.

Order number 41 provides the detail format of how to prepare a memorandum.

The memorandum of appeal will contain the grounds which the appellant will be seeking judicial
examination.

The memorandum of appeal should contain the following:

1. The pleading
2. The issues to be addressed
3. The findings in the trial court
4. The judgment of the trial court

38
Constitution of Kenya 2010 article 50(2q)
39
Constitution of Kenya 2010 article163 (4b)
40
Constitution of Kenya 2010 article 164 (3)
41
Constitution of Kenya 2010 article 165 (3c)

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It should address the areas in which the appellant seeks justice this is, where the trial judge might
have not addressed correctly in issues presented before the court.

The appeal is to be presented within a reasonable time. However, if the time for appealing
expires, the one may apply for an extension of time. (Appellant jurisdiction Act no. 4 Court of
Appeal Rules).

The court can accept an appeal but this does not necessarily mean that it will at the end of the
hearing, turn over the decisions of the trial courts.

The courts on the other hand also have the power to dismiss the appeals presented before the
appeals if they do not meet the grounds for appeal. If the court finds out that the appeal is will
not stand, then the dismissal can happen without informing the responded.

In Judicial Review application is made by way of chamber summons and is to be accompanied

by a statement setting out the name and description of the applicant, the relief sought and the
ground on which the relief the sought and support affidavit(s) setting out the facts and evidence
relied upon

REMEDIES OF STATUTORY APPEALS

Powers of the appellant court

1. The appellant court can pronounce a new judgment for a case if they think that the trial
judge misdirected himself in the proceedings presented before them.
2. The appellant court can remand the case. Here, the appellant court sends the case back to
the trial court for hearing.
3. The appellant court can identify the issues of contention and refer them back to the
subordinate court.
4. The appellant court can ask the trial court to take more evidence on the case or they may
do so they in areas where they feel that the evidence presented before the court was not
enough for the judgment given.
5. The appellant court can also order a new trial for the case.

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Bibliography

Black’s Law Dictionary 2nd edition.

Constitution of Kenya, 2010.

PLO Lumumba and Peter Kaluma, Judicial Review, Judicial Review Of Administrative Actions
in Kenya

Peter Kaluma, Judicial Review: Law Procedure and Practice 2nd edition

Michael Fordham, Judicial Review Handbook, 2012 Edition.

www.kenyalawresourcescentre.org>review.

https://ogekazacharia.blogspot.com/2017/04/judicial-review-explained-kenya-law.html.

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