Over 2024, the patience of the Kenya’s youth snapped, and a new movement has emerged to demand a return to constitutionalism. The tension between constitutionalism, authoritarianism and anarchy played out in Kenya’s courts and streets with strategic litigation by the Law Society of Kenya around enforced appearances, arbitrary arrests and the right to assembly and expression.[1]
A Constitution is search of a Country?
At least two decades of civil and legal activism and political negotiation preceded the inauguration of the Constitution of Kenya on 27 August 2010.[2] Led by lawyers, academics, professionals, politicians, students, workers and other citizens maintained a consistent pressure for constitutional reform after the struggle for a return to multi-partyism exploded in 1990.[3]
Prior to the 1990s, at least 24 constitutional amendments had been introduced to strengthen Presidential powers, outlaw independent candidates and then opposition parties, introduce repressive laws such as detention without trial and lower the threshold for the exercise of emergency powers.
The failure of the centralised state to evenly distribute economic and political development created the post electoral meltdown that devastated Kenya in 2008. With over a 1,000 killed and 10,000s displaced following the controversial 2007 General Election, trust in the National Assembly, Judiciary, Electoral Commission and the Executive at rock-bottom Kenya found itself in a constitutional moment.
The Constitution of Kenya (2010) is widely considered to be one of the most progressive constitutions in the world. It has four distinct transformative aspects. First, presidential powers enjoyed by former Presidents are now redistributed across other arms of the state. Governance and services are devolved to 47 counties to ensure all Kenyans benefitted equitably. Thirdly, the bill of rights enshrined a new framework for political, economic and social rights. Lastly, active public participation, integrity, equality and non-discrimination were proclaimed as national values and policy directives for citizens and the state. In less than two generations, Kenyan men and women went from being colonial subjects to citizens with representatives and then to active citizens.[4]
The promise of the constitution was short-lived. The 2017 General Elections led to the assumption of Uhuru Kenyatta and William Ruto to power at a time when both were still indictees before the International Criminal Court for their roles in the 2008 post election violence. Ten years after the passing of the 2010 constitution, 1 in 2 Kenyans believed that there was no equality under the law. Only 23 percent were satisfied with the rate of implementation. Twice as many people feared police brutality (49%) than poverty (21%).[5]
On 9 August 2022, one of the Constitution’s most ardent opponents prior to its promulgation William Ruto, was elected with a narrow margin of roughly 200,000 votes. In accordance with several past elections, the electoral process and results were contested first in the Supreme Court in 2022 and then the streets through April – August 2023. Behind the “sufuria maandamano” protests of 2023 lay deep unresolved grievances with the levels of inequalities, exclusion, corruption and over securitisation.
While it was civic activism that pressed through a recalcitrant state to deliver a new constitution in 2010, it was the same civic activism that ensured the constitution would protect rights and freedoms during the Gen Z protests in 2024. In this vein, Kenyans have demonstrated the power of “demosprudence”, the might of ordinary people’s actions to influence legal interpretation.
Constitutionalism, authoritarianism or anarchy, choose
Except for a highly successful anti-femicide solidarity march of 10,000 women across ten counties in January, there was no sign that 2024 would be one of the most significant year of protests in post-colonial Kenya.
Before the Gen Z mass protested erupted in June, most Kenyans had written off the youth as disenfranchised and disinterested in politics. In 2022, 6 million 18-24-year-olds eligible to vote declined to participate in a General Election that was decided by just over 200,000 votes. The trigger for the youth’s anger in 2024 was a widely unpopular Finance Bill. Several mass protests were called. The most pivotal of the protests took place on 18, 20, 25 and 27 June.[6]
Despite active submission of memoranda against the bill by the public, parliamentarians passed the bill. Thousands flooded the streets of Nairobi and other urban cities and towns across the country. The Supreme Court and County government buildings were burnt. The National Assembly was temporarily occupied on 25 June, and the mace, a ceremonial symbol of the state, briefly passed into the hands of twenty-year-old protesters.
For those few hours, Kenya seemed to swing between people’s power for some, and anarchy for others, as the power shifted away from the state to the people. While June and July may have been the most dramatic months, there were over 1,800 demonstrations or four demonstrations every day over 2024.[7] Tragically, the state crackdown on the youthful protesters was vicious. Peaceful protesters armed only with Kenyan flags, water bottles and constitutions were met with excessive and disproportionate lethal force.
Water cannons, tear gas, rubber and live bullets were used repeatedly on unarmed protesters, journalists, emergency health-workers and by-standers often by non-uniformed police agents.[8] At least 65 deaths and hundreds of injuries have been verified by the Kenya National Commission on Human Rights and other human rights organisations.[9]
More than two thousand people were arrested, held briefly and then released due to defective charges.[10] At least 89 mostly young people were abducted, detained and tortured by state agencies trained in counterintelligence and counter-terrorism methods for leading peaceful protests, expressing a political conscience or posting satirical images of the President online.[11] Most of the protesters were held longer than the statutory limit of 24 hours in solitary confinement, denied water and food and beaten during interrogation.[12] As of February 2025, at least 25 protesters are still missing.
The scale of human rights abuses is significant even by Kenyan standards. During the Saba Saba 7 July 1990 rallies for the restoration of multi-partyism and democracy, twenty people were killed. 1,056 others were charged in courts bearing visible injuries but were largely unrepresented by lawyers. Bail applications were denied or set at Kshs 10,000, a huge amount for most arrested. Many protestors sat in remand or prison for between two and 24 months.
Despite this, the Kenya Broadcasting Corporation, the only mass media station at the time, gave the events a black out. There were no registered human rights organisations or policing oversight agencies. Consequently, no police officers were prosecuted for using excessive force.[13] The number of people killed in 2024 is three times the number killed in 1990 while the number arrested is twice those arrested.
Unlike 1990, the human rights abuses provoked several responses from citizens, human rights organisations, medical and legal professional associations. Between June and December, volunteers offered to observe and report on the protests. Rallied by Medics4Kenya and the Kenya Medical Association, medical camps were organised to provide emergency care to protesters, police officers and bystanders.
Pathologists were mobilised to independently carry out postmortems, investigate and document deaths. High level policy dialogues were convened to restrain law enforcement agencies from breaking the laws they swore to uphold. Unlike 1990, these actions were carried by most of Kenya’s 60 media stations. Social media platforms emerged as powerful places for mobilisation and public education.[14] Strategic public interest litigation was also a key pillar in protecting the right to protest and upholding constitutionalism over 2024.
Strategic litigation to protect the protester and uphold constitutionalism
Over 2024, strategic litigation initiatives sought to protect the right to assembly, legal representation and a fair trial, freedom from excessive use of police force, unregulated deployment of the military, the right to life and freedom from enforced disappearances, cruel and inhuman treatment during detention.
1.Freedom of Assembly and Right to legal representation
Article 37 of the Constitution of Kenya guarantees every citizen the right to assemble, demonstrate, picket, and present petitions to public authorities peacefully and unarmed. The right to assembly began 2024 battered and bruised. Despite the killing of at least 31 protesters and bystanders during the March to July 2023 protests, authorities had failed to ensure justice. [15]
In June, the Law Society of Kenya sued the Police Inspector General for arresting over 400 protesters but not charging them with any offences in a court of law. They argued that the arrests were arbitrary and were intended to suppress the right to assembly rather than evidence of criminal conduct.
One of the remarkable features of 2024 was the deployment of more than a hundred advocates all over the country to police stations to represent protesters and secure bail. Incredibly, most of the two thousand people who were arrested were held briefly, released on free bond or unconditionally.[16]
In July, Katiba Institute sued the Police Inspector General for issuing a press release forbidding any demonstrations in the Nairobi Central Business District. [17] In December, the Law Society of Kenya filed suits to protect protesters against criminal charges for expressing their freedom of speech. This included Tyson Kiriago who was arrested for wearing a “Ruto must go” t-shirt in December and Morara Kebaso who was arrested for committing “a public disturbance and breach of the peace”.
Lawyers argued that the Office of the Director of Public Prosecutions application of Section 95(1)(b) of the Penal Code in the latter case criminalises freedom of public expression. Further, the provision is rooted in counter-insurgency fears during the colonial period and offends free speech under Article 33.[18]
2.Police Brutality Against Protesters and respect for court orders
The United Nations’ Basic Principles on the Use of Force and Firearms by Law Enforcement and the United Nations Human Rights Guidance on Less-Lethal Weapons in Law Enforcement places several obligations on the Kenyan police service. Police officers must always identify themselves and avoid use of force on peaceful protesters or restrict such force to the minimum extent necessary. Lethal force should only be used when strictly necessary to prevent an imminent threat to life. Police should also not use excessive force on detainees in their custody.[19]
Over 2024, the Law Society of Kenya filed several cases on behalf of survivors and victims’ families that were injured or killed in the 2024 protests. The suits sought accountability and compensation for the human rights abuses.[20]
Petitioned by Advocate Saitabao ole Kanchory, Justice Thande prohibited the National Police Service from using water cannons, tear gas, live bullets and other lethal and less lethal force against protesters. The Judge directed the Police Inspector General to enforce police identification laws. This requires police commanders to withdraw all security officers deployed in masks, without uniforms and security vehicles without license plates to wear name tags and ensure police vehicles remain clearly marked.[21]
On 28 June, the High Court of Malindi barred the use of water cannons, tear gas, live ammunition, rubber bullets or other crude weapons and the deployment of brute force. The court orders outlawed the state from "committing any extrajudicial killings, arrests, abductions, detentions, intimidation, torture, cruel, inhuman and degrading treatment" against peaceful protesters.[22] Outrageously, both court rulings were repeatedly flouted as police officers committed abuses against protesters and avoided being held accountable by hiding their identities.
The last three months of 2024 saw two other significant cases prosecuted in Kenyan courts. The first was the charging of Police Commander Titus Yoma and 11 senior police officers with 47 counts of command responsibility for sexual assault, torture, murder and crimes against humanity committed under the International Crimes Act.
The case is first time that Kenyan authorities have invoked the international statute domestically to seek justice for sixty people whose rights were violated in their homes in a night police operation in the informal settlements of Kisumu during the 2017 General Elections. Worryingly, the Office of the Director of Public Prosecutions seem to have caught cold feet and have sought four deferrals for plea-taking between October 2024 and February 2025.[23]
On December 31, High Court Judge Jairus Ngaah ruled that the Police Inspector General be personally liable for issuing unconstitutional orders that violated individual’s rights during peaceful protests. Citing Articles 36, 37 and 41 of the constitution, the ruling found that the Police Inspector General Japhet Koome erred in his directives to police officers under his command to violently disrupt the Kenya Medical Practitioners, Pharmacists and Dentists Union members’ peaceful march in April 2024. The action led to the serious injury of their Secretary General Davji Atelah while leading industrial protests by the doctors at that time.[24]
This ruling now opens the door for any individual to sue the Inspector General for all forms of police brutality resulting from his orders. The Interior Cabinet Secretary has since declared the government will appeal this ruling.[25]
3.Deployment of the Kenya Defence Forces to respond to protesters
The Defence Cabinet Secretary unilaterally and without the consent of Parliament deployed the Kenya Defence Forces to protect critical infrastructure in the aftermath of the 25 June occupation of the Parliament. The Law Society of Kenya unsuccessfully sought the High Court to direct the government to declare guidelines and timelines for the deployment of the Kenya Army to protect critical infrastructure in the aftermath of the 25 June protests. [26]
Amnesty International Kenya and the International Commission of Jurists-Kenya Section released Human Rights-Based Guidelines on the Deployment of the Kenya Defence Forces in the Context of Protests in Kenya. The advisory demanded the Kenyan army operate within the bill of rights. They argued that given Kenya was not in a state of civil war, nor did a national emergency exist, President remained the Commander in Chief and the Police Inspector General accountable for all policing functions.
Soldiers could be held individually accountable and subject to oversight by the Kenya National Commission on Human Rights and the Independent Policing Oversight Authority. Rather than a military tribunal, they could be subject to prosecution in a civilian court by the office of Director of Public Prosecutions.[27] In January 2025, the Government has not revoked the deployment of the armed forces seven months on.
4.Right to life and freedom from cruel and inhumane treatment
Under the International Convention for the Protection of All Persons from Enforced Disappearances, no one should be subjected to an enforced disappearance even during the time of war. An enforced disappearance is the arrest, abduction and detention of a person incommunicado and outside of the court’s jurisdiction by state agents. [28]
Habeas corpus applications were a consistent feature of human rights based legal activism in the 1980s and 1900s one party state. Over the last two decades they have been rarely applied in politically related cases. There have, however, been several cases of abductions and enforced disappearances over the last decade mostly connected to anti-terrorism cases.[29]
Backed by online media campaigns, media work and lobbying by victims families, citizens, civic and political leaders, Law Society of Kenya lawyers successfully intervened on several occasions to uphold the rights of Kenyan protesters not to be subjected to enforced disappearances and arbitrary detentions.[30]
Although Kenyan law allows police to hold suspects for no more than 24 hours without taking them to court, police detained protesters for weeks in police cells and unregistered places such as forests, abandoned buildings, and warehouses. Kenyan authorities also deployed security personnel to track, intimidate, and threaten protesters and social media activists. Many people interviewed said that people they believed to be security officers had tracked them and kept them under surveillance.[31]
The Law Society of Kenya filed three sets of habeas corpus applications for 25 citizens who had been abducted by state officers under certificates of urgency.[32] They included Bob Njagi, Jamil and Aslam Longton, Billy Munyiri Mwangi, Ronny Kiplangat, Peter Muteti, Bernard Kavuli, and Gideon Kibet. The citizens were held incommunicado and in undisclosed locations for between fourteen and thirty-two days before being released.
The applications were largely successful. Mandatory orders were granted for the production and unconditional release of the abductees and judges made it clear that enforced disappearances will not be tolerated. While not without resistance, the Police Inspector General and Director of Criminal Investigations were finally compelled to attend court and be cross-examined on the whereabouts of abductees. The rulings did not escape retaliation. At one point, the authorities responded by withdrawing the judge’s security detail.[33]
These applications coupled with behind-the-scenes policy lobbying, mass media and social pressure had led to the release of most abductees. The case of Justus Mutumwa and Martin Mwau and that of Yussuf Ahmed were not so fortunate. Both Mutumwa and Mwau were found murdered days after witnesses alleged, they were abducted by police officers.[34] Their colleagues Steven Mbisi Kavingo and Kalabi Mwema as well as Ahmed remain missing persons in January 2025.[35]
On 4 September, the Law Society of Kenya sued the Nairobi Regional Police Commander and former Police Inspector General for the arbitrary shooting of a protester David Chege opposite the Senate on 25 June 2024. The prayers noted that his death had not been subjected to a prompt, independent or thorough investigation, his family had been denied justice, and the killers were still at large.[36]
Despite the enactment of the National Coroners Service Act (2017),[37] the police dominance over forensic investigations remains a major impediment to independent investigations in cases where police officers are implicated. On 21 August, Nairobi County Government notified the public that they intended to bury 120 unclaimed bodies within seven days. Their suspicions were confirmed by an investigative media outlet several months later.[38]
Given allegations that many of the protesters may have been killed and anonymously buried, the Law Society of Kenya moved to court to demand that the bodies be identified.[39] Following representation by Amnesty International, the Independent Medical Legal Unit and the Law Society of Kenya, the Nairobi City Government and Nairobi Funeral Home ensured that independent pathologists were at the postmortems.
5.Threats Against Civil Society, Media
The Law Society of Kenya challenged the decision by the State Department of Broadcasting and Communications to restrict public sector advertising to one media house Africa Media Limited and The Star Publications Limited at the exclusion of others.[40] The move was widely criticised as punishment for the critical stories being published by the other major media houses.
In July, some media outlets further reported that the authorities summoned their editors and threatened them over live coverage of the protests.[41] Kenyan media subsequently stopped the live coverage of the protests. President Ruto declared that while he had the power to do so, he had chosen not to shut down media over the live coverage of protests.[42]
In the same month, however, President Ruto publicly accused the Ford Foundation of financing civil society organisations to fund the protests. The Public Benefits Organisations Regulatory Authority called the Directorate of Criminal Investigations to investigate 16 CSOs including Kenya Human Rights Commission, Transparency International, TISA, Katiba Institute among others.[43]
While this paper’s focus has been on the power of the Kenya bar, it is important to briefly touch on the role of the Office of the Public Prosecutor and the Judiciary during this intense moment.
Role of the Office of the Director of Public Prosecutions
The Office of the Director of Public Prosecutions is established by the Constitution of Kenya as the National Prosecuting Authority. It has the powers to direct the Police Inspector General to investigate all crimes. It is also bound to hold the interests of justice for the public and to protect the integrity of the legal process. [44]
The ODPP has not successfully prosecuted a single case against police officers or their commanders arising from the 120 deaths of protesters killed over 2023 and 2024. Victim families have complained that they have not been kept abreast of investigations. The Independent Police Oversight Authority has publicly called for their agency to be given prosecutorial powers to avoid delays and cases stalling after the ODPP declines to prosecute.[45]
Despite several public violent incidents seen by millions, the Director of Public Prosecutions statement has publicly stated they do not enough evidence to charge a single police officer for the 2024 protest violence.[46] This has further damaged the reputation of the authorities charged with investigating and oversighting police excesses.[47]
In a worrying instance, the ODPP unsuccessfully sought pre-detention orders to hold Senator Okiya Omtatah and 22 other protesters for 14 days after they organised protests to demand the release of six people abducted and held incommunicado over Christmas.[48] The use of pre-trial detention to circumvent the rights of suspects and a fair trial was rife in the 1990s. This, and the acquiescence to “orders from above” heavily contributed to the deterioration of public faith in the justice system in the 1990s.[49]
More encouragingly, the ODPP has also exercised its decision guidelines to not charge scores of protesters who were brought before the court with defective charges or had been held for more than the statutory period of 24 hours.
Role of the Judiciary
The Constitution of Kenya enshrines the expectations of all Kenyans for a government based on values of human rights, social justice and the rule of law. The principle of equal access under the law requires it to apply in every circumstance and for all, not just some. The Kenyan Judiciary is a central player in this.
Since COVID-19, Kenyan courts have developed a robust jurisprudence on the use of police force.[50] On 25 June, the Chief Justice proactively announced that judges would be available to hear habeas corpus applications outside of normal working hours.[51] In her address to the High Court Summit in December, she noted that the one of the “High Court's significant achievements was its defence of the right to peaceful assembly and protests by charting a delicate balance between law enforcement and the constitutional right to peaceful protests.” [52]
2024 closed with a concerted online and legal campaign by some senior lawyers to dismantle the Supreme Court and remove the Chief Justice. While likely to be related to the role of the Supreme Court in deciding electoral disputes and the 2024 General Election, it is not far fetched that the campaign has been triggered by the Judiciary’s independent protection of human rights and constitutionalism.
In closing, it is worth noting that the role of the police in a democracy is not to pronounce guilt, pronounce sentences, execute suspects or even to defend Governments. It is to uphold the law, apprehend suspects and hand them over to prosecutors and judges to find them guilty. For this model to succeed, the independence of the ODPP and the Judiciary is paramount.
Conclusion
While the focus of this paper has been to capture strategic litigation that protected protesters over 2024, it is important to not omit the many other cases that the advocates of the Law Society of Kenya have undertaken. This includes the successful application to stop the lease of Kenya’s power transmission infrastructure and Jomo Kenyatta International Airport to a foreign private entity Adani Energy Solutions.
While strategic litigation has been effective in stopping human rights abuses, it has been less successful yet in holding officers and their commanders responsible for criminal actions taken while discharging their duty. The President and other senior government officers have chosen to remain silent, deny the human rights abuses[53] or promise action without follow up to date.[54]
As of January 2025, the authorities have yet to disband the multi-agency unit responsible for abductions and arbitrary arrests and suspend officers and their commanders. Given the blue code of silence and protection from “above” it is time the Kenyan Parliament review police oversight laws, and the Kenya National Commission on Human Rights and the Independent Policing Oversight Authority establish an independent tribunal consisting of Kenyan and non-Kenyan investigators, prosecutors, and judges to prosecute protest-related crimes.
Consistent with its commitment to sit on the UN Human Rights Council and ahead of the 2025 Universal Periodic Review, the Government should accede to requests by several of the United Nations special rapporteurs, including the rapporteur on the right to freedom of assembly and association and the rapporteur on extrajudicial, summary or arbitrary executions, to visit and investigate abuses that have been pending for years.[55]
Constitutions are fragile organisms. Without a “fierce urgency of now” mindset we cannot protect Kenya from authoritarianism or anarchy. Towards the end of 2024, this author presided over a gala dinner at which the Law Society of Kenya acknowledged the efforts of 153 advocates who provided pro bono legal support to protesters in several police stations and court rooms across Kenya. Many of the advocates who received awards were themselves, young lawyers.[56]
This paper is dedicated to courage of human rights defenders, lawyers as well as all the police officers, prosecutors and judges who clearly understood their role during this constitutional moment.
[1] This paper is work in progress and will be finalized following conversations after several public lectures to universities in Kenya and the United States of America over 2025. The author is especially thankful to Hosea Manwa, LSK PIL Convenor and Programme Officer of Law Society of Kenya Wangari Kangai and colleagues from Amnesty International, The Police Reforms Working Group, Kenya National Commission on Human Rights, State Officers (who cannot be named yet) and several others who acted to protect protesters over 2023-2024. Written by an active player in several of the moments it reviews, the author apologises in advance for any blind spots in the analysis.
[2] Https://Katibainstitute.Org/Wp-Content/Uploads/2021/08/Kenyas-Constitution-Instrument-For-Change.Pdf
[4] Irungu Houghton “Dialogue and Dissent: A Nation in Search Of A Constitution” (2023) https://www.irunguhoughton.org/thebook254
[5] Https://Www.Amnestykenya.Org/Katiba-At-10-Distressed-Yet-Defiant-A-Citizens-Scorecard-On-The-First-Decade/
[6] For A Full 2024 Timeline Https://Www.Wikiwand.Com/En/Articles/Kenya_Finance_Bill_Protests#13_May_To_18_June_%E2%80%93_Online_Mobilization
[7] Https://Acleddata.Com/2024/12/12/Despite-A-Crackdown-On-Gen-Z-Demonstrations-Dissent-Persists-In-Kenya/
[8] Https://Www.Amnestykenya.Org/Kenya-25-June-2024-End-Police-Use-Of-Unlawful-Force-Time-For-Accountability-And-Justice/
[14] Https://Theconversation.Com/Kenya-Protests-Gen-Z-Shows-The-Power-Of-Digital-Activism-Driving-Change-From-Screens-To-The-Streets-233065
[17] Hccrpet/E349/2024 Katiba Institute Vs State Law Office
[18] Petition Hcchrpet/E573/2024 Challenging The Constitutionality Of Section 95 (1) (B) Of The Penal Code - Milimani Hcchrpet No. E573
[19] Https://Www.Ohchr.Org/En/Instruments-Mechanisms/Instruments/Basic-Principles-Use-Force-And-Firearms-Law-Enforcement
[20] Pet/E303/2024 LSK & Irene Akoth Otto Vs State Law & Moses Mutayi & 1 Others and The 15 October Case Of 5 Year Old Gianna Makel Shot In Kahawa
[21] Hccrh Pet 373/2024 - LSK V Martin Mbae, Isiah Murangari & 6 Others
[22] https://www.amnesty.org/en/latest/news/2024/07/kenya-security-services-must-respect-fundamental-rights-during-nationwide-protests/
[23] https://www.irunguhoughton.org/post/public-pressure-led-to-release-of-4-abductees-now-let-police-account
[24] https://www.standardmedia.co.ke/health/index.php/national/article/2001509274/court-inspector-general-of-police-can-be-held-liable-for-police-brutality
[25] https://eastleighvoice.co.ke/high%20court%20judge%20jairus%20ngaah/104119/interior-cs-murkomen-to-challenge-court-ruling-holding-police-ig-liable-for-junior-officers-actions
[26] Hccr Petition No. 307/2024 Law Society Of Kenya Vs State Law Office, Cabinet Secretary Of Defence And Others
[27] Https://Icj-Kenya.Org/News/Human-Rights-Based-Guidelines-On-The-Deployment-Of-The-Kenya-Defence-Forces-In-The-Context-Of-Protests-In-Kenya/
[28] Https://Www.Ohchr.Org/En/Instruments-Mechanisms/Instruments/International-Convention-Protection-All-Persons-Enforced
[32] This Included Hccrh Pet 714/2024 – Peter Muteti, Rony Kiplangat, Steve Kavingo & 5 Others V Knchr, Icj & 15 Others Hcchr Pet 305/2024 And Justis Mutumwa, Karani Muema And Three Others (Hcchr Pet E009/2025).
[33] https://www.citizen.digital/news/judge-lawrence-mugambis-security-withdrawn-after-jailing-deputy-ig-masengeli-n349610
[35] Hccr Petition No. Habeas Corpus For Yussuf Hussein Ahmed Hcchrpet/E602/2024.
[36] Hcchrpet/E378/2024 Brian Kinyanjui (As Brother Of David Chege-Deceased) Vs Adamson Bungei And Japheth Koome Former Ig Police
[37] https://www.knchr.org/Portals/0/Handbook%20On%20The%20National%20Coroners%20Service%20Act%2C%202017_2018.pdf
[38] https://www.reuters.com/world/africa/how-kenya-police-cover-up-killings-anti-government-protesters-2025-01-06/
[39] Nairobi Hcchrp No. E449 Of 2024: Law Society Of Kenya Vs Nairobi City County & Others
[40] Petition No. Hcchrpet No E083 Of 2024 Law Society Of Kenya Vs Attorney General & Others
[41] https://www.citizen.digital/news/communications-authority-warns-kenyan-media-over-coverage-of-anti-govt-protests-n346101
[42] https://www.the-star.co.ke/news/realtime/2024-07-29-i-had-powers-to-shut-down-media-during-protests-but-i-didnt-ruto/
[43] https://www.theafricareport.com/356550/kenya-investigates-16-civil-society-groups-over-alleged-protest-funding/
[44] https://www.klrc.go.ke/index.php/constitution-of-kenya/132-chapter-nine-the-executive/part-4-other-offices/325-157-director-of-public-prosecutions
[45] “IPOA Submits Its Proposal to National Dialogue Team,” September 29, 2023, video clip, YouTube, Presentation before the National Dialogue Committee, https://youtu.be/QIqg6gFMWeA?si=UYFHsrsLAy8eFZK4 (accessed November 12, 2024).
[46] https://nation.africa/kenya/counties/nairobi/dpp-i-need-witnesses-to-prosecute-police-protesters-deaths-4701172
[47] https://nation.africa/kenya/counties/nairobi/dpp-i-need-witnesses-to-prosecute-police-protesters-deaths-4701172 The ODPP has also been widely criticized for the repeated withdrawals of high level corruption and economic crimes cases of individuals connected to the current national administration https://www.standardmedia.co.ke/national/article/2001503138/inside-dpp-ingonga-struggle-to-prosecute-corruption-cases
[48]https://eastleighvoice.co.ke/office%20of%20the%20director%20of%20public%20prosecution/100875/prosecutors-want-anti-abduction-protesters-held-for-14-days-as-they-seek-phone-data
[50] https://theconversation.com/kenya-abductions-the-powerful-legal-shields-citizens-and-courts-can-use-expert-247008
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