Wednesday, 10 September 2014

Critique the two decisions: Republic v KNEC Ex-Parte Afrah Farid Maree & 48 others & Republic v. The Kenya National Examinations Council & Another, ex parte Busara Forest View Academy Limited & 94 Others. Kenyan Administrative Law

In the Farid case the Applicants sought order to quash the decision of KNEC from cancelling the results of 48 of its candidates this cancellation was communicated to the applicants by a letter dated 25th February 2010 to the respective head teacher of the students whose results were cancelled, as KNEC in the said letter alleged collusion in the mathematics and business papers respectively. A further order of certiorari to quash the decision that KNEC had come to of barring the students from participating in the exams for the next two years, this decision was rescinded, the applicants further pleaded for an order of mandamus to compel the council to  release the results of the business and mathematics paper and if possible produce the transcripts in court for the courts assessment.
Mr. Adan contested that the respondents had violated an enshrined principle of law which is the non- retrospective application of the law, this is enshrined under Art.50 (n) of the Kenyan constitution. It is stated that the cancellation of the results as well as the later rescinded 2 year ban were enshrined in Rule 26 in the Kenya Certificate of Secondary Education Examinations Rules 2009[1]. Came into force on of 4th December, 2009.whereas the exams were conducted on October and September 2009, thereby when the students sat for the exams the only penalties they were aware of where the penalties enshrined in rule 28 of the 1998 rules[2].  This is a clear contravention of the doctrine. This undermines the rule of law. Mrs. Kiarie learned counsel for respondent in replying silently noted that they had rescinded the two year ban which is enshrined under the 2009 rules but what about the cancellation? I am of the view that it wasn’t worthy as the 1998 provided for withholding of the results until the end of investigations upon which the meritable action to do would suffice which in this scenario was to cancel the results as evidence of collusion emerged.
Mr Adan Argued that the decision was ultra vires due to not according the affected students a hearing before the cancellation, he relied on the 1998 rules which state that “The Council reserves the right to withhold the results of the examination for any candidate or group of candidates or examination center suspected of having been involved in examination irregularity or misconduct pending completion of investigations and the final disposal of any consequent disciplinary or other proceedings”[3].
His construction of this was that a party must be accorded fair hearing before the cancellation of the results, in supporting this he relied on general decisions[4] that really don’t support decision making of such a body as KNEC which due to confidentiality upholds the integrity of the national examinations. KNEC cannot be expected to accord the 1000 and something students whose results were cancelled a fair hearing further counsel Kiarie was of the view that the right to a fair hearing is not absolute and is subject only to a promise[5], of which is absent even in rule 28 of the1998 rules. Her point stood. As the public interest in the examination process superseded the individual interests of the students affected, some things must be taken in trust and good faith as there is no evidence as to why KNEC would be malicious towards the ex parte applicants. further it was held that KNEC had the requisite discretion to do things in a manner that seems fair to them vis a vis upholding integrity and that they were not under an order to carry out the process in a particular meaning that accords fair hearing. If the clause of the statute is silent as to a particular manner then it is for KNEC to conduct themselves in a manner they see fit[6]. This was fair as government departments are not expected to conduct their businesses as Courts of law and therefore could act according to their routine[7]. If this rule was to be applied literally hen we will have put a spoke in the wheels of justice thereby bringing it to a grinding halt[8].
The Applicants further contested that the rules strictly state that evidence of collusion must be detected during the exam period and that it is the invigilator to detect the collusion and write a letter but it was submitted that the stages of detecting exam collusion is a tow tier process.1st is during the actual examination process and 2nd is during the marking process.[9]
A futile ground that the respondents acted capriciously, maliciously towards the applicants result of not according a fair hearing was pursued but it was submitted that there is no evidence as to why out of 600000.students that did the exam why would the 48 be targeted specifically, according them a fair hearing would be too heavy a burden to bear[10].
Where there is a necessity for speed then K.N.E.C in its own discretion should have accorded the applicants a post decisional hearing for the simple reason of maintaining administrational efficiency as well as fairness to the individuals.[11] They need not worry that this will affect the finality of their decisions as the authority who proceeds to post decisional hearing will have a closed mind and there is hardly any chance of getting a proper consideration by the representation at such post-decisional opportunity[12], only in very exceptional circumstances which of course are in KNEC’s discretion to decide as they please. Only is such a way will the principle of proportionality be balanced between the public interest, the goal being sought and the interests of the Applicants.
Order of mandamus was not applicable as the matter of examination involved discretion and compelling he body to produce the examination results and transcripts or to assess them in a particular way would hinder the future integrity and security of the examination process. Mandamus in discretionary and the court are not obligated to grant it further It naturally flows from when the certiorari is granted which in this scenario was not. I agree with the Court in this regard as Mandamus to produce the transcripts in court is not a right[13] and backed by no statute[14] as it falls under the Respondents discretion.
Accordingly the orders sought were denied and the Applicants were slapped with the Respondents costs, as they had impliedly wasted the courts precious time. 
The Busara decision: this decision was decided earlier that the Farid case, it was decided in 2009. Kibe Mungai was the learned counsel for the applicants and Mr Ngatia as well as Mrs. Kiarie for the respondents. Here the results of 96 students were cancelled after it was found that they had cheated in the English exam,  the applicants moved to court to ask for an order of certiorari to quash the decision of the council for cancelling results, an order of mandamus directing the respondents to release the English results, upon granting the first two prayers a further mandamus to direct the respondent to issue the 96 students with certificates and order of prohibition restraining the second Respondent from filling 96 vacancies in the relevant secondary schools. This is a major difference from the Farid case to this in that what was being asked here was not asked for in Farid .lastly that an order of mandamus be issued to compel the 2nd respondent to admit the 96 students in the relevant secondary schools. The applicants in asking for these rare instances of the order such as the prohibition of filling 96 vacancies and admitting the 96 students to the vacancies sought inspiration from the decision of GilGil Milimani Academy Ltd & 17 others v KNEC and 2 others.
Similarly the Applicants contested that the decision to cancel the results of the 96 students was capricious, malicious, baseless because no evidence of collusion had been provided that the rules of natural justice specifically no person can be condemned unheard were flouted by KNEC. KNEC submitted that it could not produce results that it did not have as it had already obliterated the cancelled results.
The Applicants submitted that the decision to cancel the results was beyond their jurisdiction as no evidence of collusion had been established post the computer flagging, the collusion was detected by a computer software progress that detected collusion through certain answer patterns Vis a vis calculations of probability. And that it had detected errors in the business as well as English papers.  The applicants contended that KNEC cannot hide behind rules of examinational conduct and integrity and ought to accord the students a right to fair hearing. Respondents assured the Court that the same scientific method that they use is used all over the world and that it ability to act fairly or make mistakes cannot be questioned as it would greatly undermine future conduct. The courts if allowed this would be too heavy a burden to bear and that it would be absurd to expect the students to inspect the examination marking process as it would undermine the process and hinder on the finality of decisions[15] that needs to stem from it, this specifically applies to the claim the applicants in the Farid case sought to bring the relevant exam sheets in court for the court assessment.
On the issue of a legitimate expectation to be heard it was argued that the students had clearly been warned from the circulated circulars, media and even during the rehearsal day. And that the power to cancel examinations vested in the reg. 15 and that the school attempted to arm twist the law when they attempted to contact the permanent secretary of the ministry to intercede on their behalf and it was submitted that this is a further examination irregularity.
Counsel Ombwayo for the second respondent also submitted his case after Mr. Ngatia and the court decided to summarize the issue to be tried.
The first issue was whether there was a misjoinder of parties to the case as the Respondents contended that Order 1 (a) of the civil procedure rules did not apply to the present case as a prima facie construction of it states that any parties who are affected by as a result may sue as a group in a matter where if sued individually then there would arise the same matters of issue and facts of law. But what was the problem was that the applicants did not seek court leave to file, but this being a matter of public interest the judge adopted the judicial Restrain approach, where procedural technicalities are ignored for the greater good.
The next question was whether the issue was justiciable, meaning the decision to cancel the results of the said students. KNEC being a statutory body established under the KNEC act is a governmental public body and thus any decision it makes can be subject to a judicial review. Ad that the right s of the Applicants (1st and 2nd) has been infringed. The courts held that it was subject to review sir John Donaldson said in R v Panel on Takeovers and Mergers ex p. Datafin plc (1987) Q.B 815 that statutory and non -statutory bodies can be subject to judicial review on the same basis in defense of the citizenry.
Whether the decision of the council was ultra-vires- the council was created by s.3 (1) and (2) of the KNEC Act as a separate legal entity. The council had power not only to conduct but to also cancel the results of students who are found to have cheated, the applicants submitted that the respondents had not produced evidence to that effect they relied on the affidavits of the invigilators who claimed to be no collusion but the respondents claimed that they detect collusion using a software known as the Optical marker readers[16] and it is based on a balance of probabilities where it detects anomalous deviation o not right but wrong answers and that this system was trustworthy and had been adopted internationally by many institutions for its rate of success. The courts adopted a purposive approach to oversee why the council had cancelled the results of 96 whereas regulation 15 of the KNEC act provided for a cancellation of all the results at the center if there is evidence to prove that he collusion was widespread the courts noted also that purposively the power of the council to facilitate examinations carried a tail-right to cancel[17] results if misconduct is found. It was found while seeking inspiration from some case law[18] that the council was within its jurisdiction when making the decision to cancel the results.
Whether they had a right to a fair hearing? On the allegation of non-production of collusion evidence then he court was of the view that in judicial review they are only concerned with the process that was followed in coming to the decision but not to the decision’s efficacious nature.[19]
The courts found that as a general right there is no right to a fair hearing when it comes to education bodies as this would inter alia mess up with the integrity of the conduct of exam, it would be time consuming, lay a heavy burden on the council etc. however as I had already dealt with this right in the previous case then it is of advice that its time KNEC consider the post decisional hearing so as to avoid the floodgate of cases that are coming to court against them for a literal construction of the rule of fair hearing. Keeping in mind that as a general rule the post decisional hearing should make no difference[20] to the decision except in special circumstances
Whether the council could release the composition paper? The applicants futile plea was that they be released the results of the composition paper which had been cancelled alongside the English paper as both marks are normally added together then presented as one mark in the transcript of results. The respondents urged that they could not produce results that they do not have as they had already cancelled it after evidence of collusion was found: all in the spirit of upholding the integrity of the examination process.
Whether they had a legitimate expectation to be heard? As I had argued in Farid here there was no promise and thus there was no legitimate expectation to be heard as the matter herein consists of a public interest of which supersedes the interest of the individuals concerned as this would undermine the countrywide examination process in terms of security, confidentiality and integrity.
The Applicants further contended that the decision to cancel the results was unreasonable and thus carried out in bad faith, since they only cancelled 96 and not all the candidates as the rules stated with regard to massive evidence of collusion, the degree of unreasonability is very high and thus the respondents failed to satisfy the threshold.
Further they argued that it was in bad faith as also the composition results were cancelled however it was held that English and the exam paper are normally later combined to make one grade as a such when one misses then the other loses meaning. [21]
Duty of Candor: duty of disclosure of all the relevant material facts as has been stated in very wise words that judicial review must be approached with all the cards facing upwards for all to see[22]. Respondents established that all evidence of collusion was accurate according to the recognized software, Applicants contended that the exams were done in strict conditions giving no room for collusion however from the affidavits submitted; the students had not sat 1.22 meters apart instead it was one and that it was unclear who frisked the girls and boys in some rooms as those rooms only contained one invigilator of a specific gender whereas the rooms contained students of a mixed sex. It was found that the respondents had not breached any duty of candor equally the applicants hadn’t as this duty applies to both sides.
The applicants considered the Children’s Act and claimed  a violation of the right to education however the court found that they were underserving as when they came to court they violated the Clean hand doctrine, which states that he who seeks equity cannot come in hands covered in blood, the Applicants came with dirty hands as they had  tried to contact the permanent secretary for  education to intervene in the matter, the irregularities that were observed during the exam came from the affidavits in support of the applicants thus they didn’t have clean hands. The court must have held this because a breach of the clean hands doctrine amounts to willful misconduct that is unfair, dishonest, and fraudulent and any action the state takes will have been performed in bad faith.[23]




[1] Legal Notice No. 176
[2] Legal Notice No. 18 of 1998
[3] Rule 28
[4] The Commissioner of Lands v. Kunste Hotel Limited Civ. App. No. 234 of 1995 [1997] e KLR: Republic v. The Kenya National Examinations Council, ex parte Kemunto Regina Ouru, Eldoret Misc. Civ. Application No. 1 of 2009 [2009] eKLR.
[5] R.V.P Wendoh-Republic v. The Kenya National Examinations Council & Another, ex parte Busara Forest View Academy Limited & 94 Others.
[6] University of Ceylon v. Fernando [1960] 1 All E.R. 631
[7]Lord Shaw - Local Government Board v Arlidge 1915 A.C 120
[8] Page 256
[9] Busara decision; Lord Pearson-Pearlberg v. Varty (Inspector of Taxes) [1972] 1 WLR 534
[10] Kenya National Examinations Council v. Republic,  Civil Appeal No. 266 of1996,
[11] Maneka Gandhi v Union of India 1978 1 SCCC 248
[12] H.L Tehran v Union of India 1989 1 SCC 764
[13] S.P Manocha v the State of M.P AIR 1973 MP 84: Court could not compel a school to admit a student as they failed to establish a right of admission.
[14] Union of India v Orient Enterprises 1998 3 SCC 501
[15] Maharashtra State Board of Secondary and Higher Education v Kurmasheth 1985 LRC 1083
[16] Page 35 of the judgment (Busara)
[17] Page 37 of the judgment ibid
[18] Anisminic Case ; Ex Parte Saitoti case
[19] Page 40 of the ruling.
[20] John v Rees 1970 Ch 345
[21] Page 55 of the ruling
[22] R v Lancashire County Council ex parte Huddleston 1986 2 All ER 941
[23] Precision Investment v Auto Maintenance 324 U.S. 806 (1945)

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