LABOUR LAW CAT

STUDENT NAME: NICHOLAS TARENCE OTEMA RAGALO

FINAL GRADE 14/15
Critically interrogate the issue of the development of fair labour practices under
the Kenyan labour laws.
INTRODUCTION
The Kenyan Constitution stipulates that ‘every person has the right to fair labour practices’
but some commentators have noted that it falls short of comprehensively defining what
they entail.1 2 Commentators have further noted that this lack of clarity extends to the local
statutes which form the regulatory framework for labour relations. 3 If Article 41(1) is
interpreted using a contextual reading approach, one could argue that Articles 41(2), 41(3),
41(4) and 41(5) contribute to the overall definition of ‘fair labour practices’ by implying that
they include guaranteeing an employee’s rights to fair remuneration; to reasonable working
conditions; to unionise; and to industrial action. 4 In the absence of certainty, local courts
have also utilised the provisions of statutes such as the Employment Act to draw inferences
and create a foundation of what amounts to ‘fair labour practice’. 5 Some examples of this
are the provisions which relate to Termination and Dismissal contained in Part IV of that Act
(e.g. entitlement to fair hearing (Section 41), requirement for proof for reason of
termination (Section 43), prohibition of unfair dismissal (Section 45(2)). 6

The approach in jurisdictions with similar constitutional provisions, such as South Africa is
also informative in defining ‘fair labour practices’. Article 23(1) of the South African
constitution uses similar wording to Article 41(1) and states that ‘everyone has the right to
fair labour practices’.7 The nation’s Labour Relations Act expounds upon this by defining
unfair labour practices as:
 unfair conduct by the employer relating to the promotion, demotion, probation,
training, or benefits; and

1
Constitution of Kenya 2010, Art. 41(1)
2
“Development of the Fair Labour Practices Concept” (MMAN ADVOCATES, September 18, 2020);
https://mman.co.ke/content/development-fair-labour-practices-concept-0> accessed June 22, 2022
3
Ibid.
4
Constitution of Kenya 2010, Art. 41(2)
5
Supra Note 2
6
Employment Act, ss 41, 43 & 45
7
Constitution of the Republic of South Africa 1996, Art. 23(1)

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 unfair suspension of an employee or any other unfair disciplinary action. 8

It must also be noted that Kenya has been a member of the International Labour
Organization (‘ILO’) since January 1964 and has ratified 52 relevant conventions. 9 10 On this
basis, international labour standards could also be regarded as forming part of local law
pursuant to Articles 2(5) and 2(6) of the constitution to the extent that they are reflected in
the ‘general rules of international law’ and ‘any treaty or convention ratified by Kenya’.11
These include the eight fundamental conventions which the ILO has identified as containing
the foundational principles and rights at work such as the Discrimination (Employment and
Occupation) Convention, 1958; Equal Remuneration Convention, 1951; and Right to
Organise and Collective Bargaining Convention, 1949.12

In this essay, I intend to critically evaluate ‘fair labour practices’ under the Kenyan law in the
context of the above definition. I will begin with an exploration of the history and evolution
of labour relations from the colonial and post-independence periods to the present day. I
will then analyse Kenya’s current legal framework with a view to identifying any
shortcomings and confirming whether there is a pathway for reform based on the
transformative aims of the 2010 Constitution and international best practice and standards.

HISTORY AND EVOLUTION

Colonial Period
The Trade Union Act of 1871 and the Employment and Workmen’s Act (‘EWA’) of 1875 had
already been passed in the United Kingdom (‘UK’) by the time of the Berlin Conference
(1884-5) which formalised the so-called ‘Scramble for Africa’. The latter legislation was
enacted in England following a prolonged campaign by organized labour. 13 It replaced the
earlier Master and Servant Act of 1867 (‘1867 Act’) which had allowed penal sanctions when
8
Labour Relations Act (South Africa), s186(2)
9
International Labour Organization (Country Profile: Kenya) https://www.ilo.org/dyn/normlex/en/f?
p=NORMLEXPUB%3A11003%3A0%3A%3ANO; accessed June 22, 2022
10
International Labour Organisation, (Ratifications for Kenya) https://www.ilo.org/dyn/normlex/en/f?
p=1000%3A11200%3A0%3A%3ANO%3A11200%3AP11200_COUNTRY_ID%3A103315; accessed June 22, 2022
11
Constitution of Kenya 2010, Arts. 2(5) & 2(6)
12
International Labour Organistion (Conventions and
Recommendations) ;https://www.ilo.org/global/standards/introduction-to-international-labour-standards/
conventions-and-recommendations/lang--en/index.htm#:~:text=The%20ILO%20Governing%20Body
%20has,forced%20or%20compulsory%20labour%3B%20the; accessed June 22, 2022
13
Anderson D, “Master and Servant in Colonial Kenya” [2000] 41 The Journal of African History 459-485

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workers breached their contracts but limited the consequences of the same conduct for
employers to civil sanctions.14 The EWA placed employers and workers back on an equal
footing by stipulating that all breaches of contract would be covered by civil law. 15

After the establishment of the East Africa British Protectorate in 1895 and the subsequent
promulgation of the East African Order in Council of 1897, all applicable legislation in
England became part of the colony’s law.16 This effectively meant that the EWA would have
regulated local terms and conditions of employment at that point in time. 17 This situation
changed as settlers began arriving in the coming decade. Over 600 had arrived in the colony
by 1906 creating an urgent need for ‘native labour’.18 The settlers, however, felt that labour
in the protectorate was still in the primitive stages of development and that the EWA was
too progressive to apply locally.19 This resulted in the enactment of the Master and Servant
Ordinance of 1906 which was similar in spirit to the 1867 Act. The Ordinance sought to
control labour relations in colonial Kenya by introducing a system of verbal and written
contracts, prescribing offences that could be committed by employees and stipulating
penalties and dispute resolution mechanisms.20 21 A common feature with the 1867 Act was
the criminalisation of breaches of contract by workers.

This situation remained relatively static over the next two decades with subsequent
ordinances serving to further curtail the rights of workers. This period did however see
organisations such as the Anti-Slavery and Aborigines Protection Society and British and
Foreign Anti-Slavery Society taking on the issue of exploitative labour practices in the
colonies.22 The ILO was also founded in the wake of World War One in 1919 as a part of the
Treaty of Versailles with the aim of advancing social and economic justice through setting

14
Naidu S & Yuchtman N, “Coercive Contract Enforcement: Law and the Labor Market in 19th Century
Industrial Britain”, https://assets.aeaweb.org/asset-server/articles-attachments/aer/data/
feb2013/20100770_app.pdf; accessed June 28, 2022
15
Employment and Workmen’s Act 1875 (UK), s4
16
Kenya Human Rights Commission, Labour Rights and Legal Framework in Kenya, 2019
17
Ibid.
18
Supra Note 13
19
Supra Note 16
20
Touaibia MZ, “Land and Labour in Kenya under British Colonial Rule from 1888 to 1953” (thesis2014)
21
Supra Note 16
22
Okia O.J., “Forced Labor and Humanitarian Ideology in Kenya, 1911--1925 Forced Labor and Humanitarian
Ideology in Kenya, 1911--1925 ”(thesis2002)

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international labour standards.23 Increasing domestic pressure within this larger context led
to the British government taking a greater interest in the issue of labour relations in the
colonies from 1925 onwards.24 A series of economic crises during the post war and Great
Depression period, however, put this issue on the backburner as many colonial powers had
to resort to compulsory labour in order to curb their expenditure and take measures such as
imposing heavy taxes on the natives in order to compel them to work on the settler
farms.25 26
An ILO convention was held in June 1930 with a view to regulating compulsory
labour but it fell short of banning it and additionally overlooked the exploitation of
Africans.27

The degenerating labour conditions led workers in Kenya to increasingly agitate for their
rights culminating in the formation of the first local trade union called the Labour Trade
Union of Kenya by the activist Makhan Singh in 1935. 28 The colonial government responded
by enacting the Trade Union Ordinance of 1937 which required any organisations which
undertook union activity to be registered in order to operate. 29 There was a further
requirement restricting the leadership of trade unions to educated people which was
detrimental to non-Europeans in the colony owing to their relatively lower literacy levels. 30
Trade unions were also regarded as a conduit for running political activities leading the
colonial government to clamp down on them in many instances and label their leadership
and members as political agitators.31

The issues of collective bargaining and freedom of association for every person irrespective
of race, colour or sex were considered by the ILO during their 1944 conference in
Philadelphia, USA.32 The Philadelphia Charter was adopted following this meeting and in

23
“Mission and Impact of the ILO”, International Labour Organization; http://www.ilo.org/global/about-the-
ilo/mission-and-objectives/lang--en/index.htm; accessed June 28, 2022
24
Supra Note 16
25
Supra Note 20
26
Supra Note 16
27
Supra Note 20
28
Supra Note 16
29
Ibid
30
Ibid
31
Ibid
32
Chepkorir L, “Evolution of Labour Laws in Kenya” (Academia.edu, January 29,
2021) ;https://www.academia.edu/45004047/EVOLUTION_OF_LABOUR_LAWS_IN_KENYA; accessed June 28,
2022

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essence it restated the organisation’s fundamental aims and purposes and envisaged a
system of industrial relations with a view to improving living standards. 33 This heralded a
new approach to economic and social development in the colonies and boosted the
establishment and standing of trade unions based there.34 35

A notable development in the succeeding years was the enactment of the Protective Labour
Code in 1946 by the colonial government. This code was intended to reform the manner in
which native workers were treated by the settlers and helped curtail cruel labour practices. 36
It included provisions abolishing penal sanctions for breach of contract, stricter government
surveillance of labour recruitment and improvements in the recommended standards for
medical treatment, housing, and rations. 37

In the decades leading up to independence, increased union activity and dialogue between
organisations such as the Federation of Kenya Employers, the Kenya Federation of Labour
(the forerunner of the Central Organisation of Trade Unions) led to the signing of the 1962
Industrial Relations Charter. The charter committed the signatories to consultation,
collective bargaining, and peaceful dispute settlement; laid down the duties of management
and unions in relation to industrial concerns; and provided a platform of dialogue in case of
conflict.38 This contributed to easing of local trade union operations and greater clamour for
the improved welfare of workers which would begin paying dividends following
independence.39

Post-Independence to 2007
The post-independence era saw the enactment and amendment of several pivotal pieces of
legislation to regulate labour relations and safeguard the welfare of Kenyan workers. The
33
Kamau J, “An Insight into the History of Labour Law in
Kenya” ;https://johnmkamau.blogspot.com/2014/10/normal-0-false-false-false-en-us-x-none.html; accessed
June 28, 2022
34
Supra Note 32
35
Supra Note 16
36
Supra Note 34
37
Collier P & Lal D, “Coercion, Compassion And Competition: Wage and Employment Trends and Structures in
Kenya 1800-1980” (Studies in Employment and Rural Development No.
64) ;https://documents1.worldbank.org/curated/en/334341468914082728/text/Coercion-compassion-and-
competition-wage-and-employment-trends-and-structures-in-Kenya-1800-1980.txt; accessed June 28, 2022
38
Supra Note 34
39
Supra Note 32

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establishment of the Industrial Court in 1964 was regarded as a crucial step in facilitating
the resolution of labour related issues and conflicts.40

In the ensuing decades this was complemented by the enactment of the Trade Disputes Act
(Cap. 234), Employment Act (Cap.226) and Regulation of Wages and Conditions of
Employment Act (Cap. 229) as well as the amendment of the existing Trade Unions Act (Cap.
233), Workmen’s Compensation Act (Cap. 236) 1963 and the Factories Act (Cap. 514). These
six statutes were to form the core of Kenyan labour law until they were eventually repealed
in 2007.41

While some of these acts contained provisions relating to worker welfare and ‘fair work
practices’ (e.g., Leave with Full Pay and Weekly Rest Days as per Sections 7 and 8 of the
Employment Act (Cap.226)), some commentators have noted that much of this body of law
was borrowed from legislation that was operational in England at the time. 42 The laws thus
had a ‘colonial heritage’ and were regarded as ill-suited to regulate labour relations in post-
Independence Kenya.43 These statutes also had several glaring shortcomings including:

 a failure to redress the power imbalance between employers and employees;

 a lack of regulations for the informal sector;
 the contradictory jurisdiction of the Industrial Court and the High Court;
 the grant of excessive powers to the Minister for Labour; and
 needlessly complex provisions that were difficult to comprehend and fell short of
infusing a human rights based approach.44

This eventually resulted in the appointment of a ‘Task Force to Review Labour Laws’ by the
Attorney General (Gazette Notice No. 3204) on 21 June 2001 which operated within the
purview of an ILO project.45 The terms of reference for this body were a thorough

40
Supra Note 34
41
Kituo Cha Sheria, The Kenyan Worker and The Law: An Information Booklet on Labour Law
42
Supra Note 16
43
Supra Note 32
44
Supra Note 16
45
International Labour Organisation (National Labour Law Profile: Kenya June 17,
2011) ;https://www.ilo.org/ifpdial/information-resources/national-labour-law-profiles/WCMS_158910/lang--
en/index.htm; accessed June 29, 2022

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examination and review of all the labour laws in Kenya with the aim of making suggestions
for appropriate legislation to replace or amend them and to further ensure their consistency
with the Conventions and Recommendations of the ILO.46

The Taskforce officially handed five draft new pieces of legislation to the Attorney General in
April 2004 including the Employment Bill, Labour Relations Bill, Occupational Safety and
Health Bill, Work Injury Benefits Bill, and Labour Institutions Bill. 47 These bills incorporated
the obligations and commitments of the 1998 ILO ‘Declaration on Fundamental Principles
and Rights at Work’ such as the elimination of discrimination; abolition of forced or
compulsory labour; freedom of association and collective bargaining; and the right to a safe
and healthy work environment.48 They further enhanced the protection of workers by giving
the government the leeway to regulate employment relationships; further empowering
trade unions to represent workers collectively; and providing for social insurance against
unemployment, old age, disability, sickness and health, or death. 49

CURRENT LEGISLATIVE FRAMEWORK

The following five core pieces of labour legislation were enacted in 2007 shortly before the
general election:

1. Employment Act.
2. Labour Relations Act.
3. The Occupational Safety and Health Act.
4. The Work Injury Benefits Act.
5. The Labour Institutions Act.

The 2010 Constitution further builds upon this statutory framework. The Bill of Rights in
Chapter Four stipulates and guarantees fundamental human rights or freedoms and the
principles enshrined therein generally accord with internationally accepted standards for
labour rights. 50 51 These include the prohibitions on slavery, servitude, and discrimination as

46
Ibid
47
Ibid
48
Supra Note 42
49
Supra Note 16
50
Supra Note 16
51
Supra Note 34

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well as freedom of association and the rights to join trade unions and participate in
industrial action.52 As noted in my introduction, the constitutional provisions that specifically
refer to ‘labour relations’ and enshrine the right to ‘fair labour practices’ are contained in
Article 41. In Peter Wambugu Kariuki And 16 Others v Kenya Agricultural Research Institute,
the Industrial Court of Kenya noted that:53

‘…the right to “fair labour practices” encompasses the constitutional and statutory
provisions and the established work place conventions or usages that give effect to
the elaborations set out in Article 41 or promote and protect fairness at work.
These include provisions for basic fair treatment of employees, procedures for
collective representation at work, and of late, policies that enhance family life
while making it easier for men, women and persons with disabilities to go to
work.’

The provisions of the Employment Act safeguard fair labour practices by Act establishing the
minimum terms and conditions of employment and defines the benefits, duties, and
obligations of both employers and employees. 54

Some notable amendments to this particular act in the period after the 2010 Constitution
include the introduction of a prohibition on discrimination on the basis of the attributes
listed in Article 27 (Act No. 18 of 2014); the introduction of pre-adoptive leave (Act No. 2 of
2021); and provisions restraining employers from requiring clearance certificates unless
they intend to enter into a contract of service with a prospective employee (Act No. 15 of
2022).55

The constitutionality of specific provisions of the Employment Act has also been successfully
challenged. In Monica Munira Kibuchi & 6 others v Mount Kenya University; Attorney
General (Interested Party), the Employment and Labour Relations Court ruled that Section
42(1) was inconsistent with Articles 24, 41 and 47 of the Constitution to the extent that it
excluded employees having probationary contracts from the notification and hearing

52
Constitution of Kenya 2010, Arts. 25(b), 27, 30, 36 & 37
53
Peter Wambugu Kariuki And 16 Others v Kenya Agricultural Research Institute [2013] eKLR
54
Supra Note 34
55
Employment Act 2007, ss5(3), 9, 29A

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stipulations of Section 41.56 Aside from concluding that the provision was contrary to the
constitutional right to ‘fair labour practices’, the Court held that it was an unjustifiable
limitation of a right or a fundamental freedom in the Bill of Rights in violation of Article 24
and a denial of the right to ‘fair administrative action’ in violation of Article 47. 57 The High
Court and Industrial Court have also respectively held that Section 45(3) was
unconstitutional in Samuel G. Momanyi v Attorney General & Another and Nelson Ogeto
Mogaka & 15 Others v Geothermal Development Company Limited.58 59
In the former case,
the court ruled that the provision limiting an employee’s ability to complain of unfair
termination was inconsistent with the constitutional rights to human dignity, ‘fair labour
practices’, ‘fair administrative practices’, access to justice and right to a fair hearing as set
out under Articles 28, 41(1), 47, 48 and 50(1). 60

As the Employment Act currently stands other key principles of ‘fair labour practices’ such
as the right to collective bargaining, wage protection and procedural fairness are respective
covered in PART III - EMPLOYMENT RELATIONSHIP, PART IV - PROTECTION OF WAGES, and
PART VI - TERMINATION AND DISMISSAL. While the current constitutional and statutory
framework on employment and labour relations has provided an avenue for resolving
disputes about the right to fair labour practice and facilitated the consideration and
determination of every individual case on its unique merits, I share the view posited by
some commentators that we could benefit from the elimination of any remaining
ambiguities.61 62
One suggested approach would be following South Africa’s lead and
including a clear definition of ‘unfair labour practices’ in the Employment Act, which would
be comparatively easier to amend than the current Constitution. 63 64

The other core pieces of legislation such as the Labour Relations Act also help bulwark the
regulatory framework for labour relations. As with the Employment, the constitutional basis

56
Munira Kibuchi & 6 others v Mount Kenya University; Attorney General (Interested Party) [2021] eKLR
57
Ibid.
58
Samuel G. Momanyi v Attorney General & another [2012] eKLR
59
Nelson Ogeto Mogaka & 15 others v Geothermal Development Company Limited [2014] eKLR
60
Supra Note 59
61
Supra Note 54
62
Supra Note 2
63
Ibid
64
Supra Note 8

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for this is the right to ‘fair labour practices’ under Article 41 and freedom of association as
safeguarded by Article 36.65 The act, in short, provides legal guidelines for the establishment
of trade unions and employer’s organizations as well as their functions. 66 The role of these
bodies in establishing and maintaining ‘fair labour practices’ cannot be understated and one
could posit that trade unions have played an integral role in their development since the
19th Century. Two of the remaining core pieces of legislation also helped complete the
picture by providing the legal framework for employers to maintain healthy working
conditions and environment for their workers (Occupational Safety and Health Act) and
providing for ILO convention compliant laws pertaining to employee compensation for
workplace injuries (Work Injury Benefits Act). 67 It is likely that this framework will continue
to evolve to meet the changing needs of the local workforce and address any gaps that are
identified by the judiciary and legislature.

65
Supra Note 16
66
Supra Note 34
67
Ibid

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CONCLUSION
The development of fair labour practices in Kenya has been along a continuum stretching
from the gradual and tentative adoption of the legal framework that was transplanted
through colonisation. As noted above, the necessity to maintain control and unenlightened
racial attitudes initially inspired the adoption of a relatively repressive set of laws but these
were tempered and displaced owing to the growing clamour from local organised labour,
the tireless activism of the international anti-slavery lobby and the birth of transnational
organisations such the ILO which have played a pivotal role in the emergence of global
labour relations standards.

Although the post-colonial period saw the enactment of ill-suited laws with a tinge of the
oppressive attitudes which favoured employers, the enactment of the 2007 legislation
impelled by the ILOs desire to propagate the principles of its various conventions among
member states has at the very least heralded the birth of a framework which looks to
redress this traditional power imbalance.

The transformative 2010 Constitution has also been invaluable in advancing these
international principles and standards within our local legislative framework and provided a
basis for reviewing and reforming our laws. This has begun to dividends in the years
following the adoption of the Constitution with several key court decisions laying the basis
for the repeal and amendment of legislative provisions which are inconsistent with its
principles. Some commentators have however noted that the legislature has been slow to
translate this impetus into new laws.68

As noted above, the current legislative framework has some unfortunate gaps and
inconsistencies, but these will inevitably be remedied as Kenya moves towards the ultimate
realisation of the aims of the transformative constitution and our sustained and gradual
integration with the principles advanced by organisations such as the ILO in an increasingly
globalised world.

BIBLIOGRAPHY
68
Supra Note 34

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LEGISLATION
Constitution of Kenya 2010
Constitution of the Republic of South Africa 1996
Employment Act 2007
Employment and Workmen’s Act (UK) 1875
Labour Institutions Act 2007
Labour Relations Act 2007
Labour Relations Act (South Africa) 1995
Occupational Safety and Health Act 2007
Work Injury Benefits Act 2007

CASE LAW
Munira Kibuchi & 6 others v Mount Kenya University; Attorney General (Interested Party)
[2021] eKLR
Nelson Ogeto Mogaka & 15 others v Geothermal Development Company Limited [2014]
eKLR
Peter Wambugu Kariuki And 16 Others v Kenya Agricultural Research Institute [2013] eKLR
Samuel G. Momanyi v Attorney General & another [2012] eKLR

JOURNAL ARTICLES AND THESES

Ochieng OJ, “Evolution of Labour Law in Kenya: Historical And Emerging Issues” (2019) 4
International Journal of Law and Policy 1
Okia O.J., “Forced Labor and Humanitarian Ideology in Kenya, 1911--1925 Forced Labor and
Humanitarian Ideology in Kenya, 1911--1925” (Thesis:2002)
Touaibia MZ, “Land and Labour in Kenya under British Colonial Rule from 1888 to 1953”
(Thesis:2014)
Naidu S & Yuchtman N, “Coercive Contract Enforcement: Law and the Labor Market in 19th
Century Industrial Britain”,
https://assets.aeaweb.org/asset-server/articles-attachments/aer/data/
feb2013/20100770_app.pdf; accessed June 28, 2022
Anderson D, “Master and Servant in Colonial Kenya” [2000] 41 The Journal of African History
459-485
Chepkorir L, “Evolution of Labour Laws in Kenya” (Academia.edu, January 29,
2021) ;https://www.academia.edu/45004047/EVOLUTION_OF_LABOUR_LAWS_IN_KENYA;
accessed June 28, 2022
Collier P & Lal D, “Coercion, Compassion And Competition: Wage and Employment Trends
and Structures in Kenya 1800-1980” (Studies in Employment and Rural Development No. 64)
;https://documents1.worldbank.org/curated/en/334341468914082728/text/Coercion-
compassion-and-competition-wage-and-employment-trends-and-structures-in-Kenya-1800-
1980.txt; accessed June 28, 2022

WEBSITES AND BOGS

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“Development of the Fair Labour Practices Concept” (MMAN ADVOCATES, September 18,
2020); https://mman.co.ke/content/development-fair-labour-practices-concept-0>
accessed June 22, 2022
International Labour Organisation (National Labour Law Profile: Kenya June 17,
2011) ;https://www.ilo.org/ifpdial/information-resources/national-labour-law-profiles/
WCMS_158910/lang--en/index.htm; accessed June 29, 2022
International Labour Organisation, (Ratifications for Kenya)
https://www.ilo.org/dyn/normlex/en/f?p=1000%3A11200%3A0%3A%3ANO
%3A11200%3AP11200_COUNTRY_ID%3A103315; accessed June 22, 2022
International Labour Organisation (Conventions and
Recommendations) ;https://www.ilo.org/global/standards/introduction-to-international-
labour-standards/conventions-and-recommendations/lang--en/index.htm#:~:text=The
%20ILO%20Governing%20Body%20has,forced%20or%20compulsory%20labour%3B%20the;
accessed June 22, 2022
International Labour Organization (Country Profile: Kenya)
https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB%3A11003%3A0%3A%3ANO;
accessed June 22, 2022
Kamau J, “An Insight into the History of Labour Law in
Kenya” ;https://johnmkamau.blogspot.com/2014/10/normal-0-false-false-false-en-us-x-
none.html; accessed June 28, 2022
“Mission and Impact of the ILO”, International Labour Organization;
http://www.ilo.org/global/about-the-ilo/mission-and-objectives/lang--en/index.htm;
accessed June 28, 2022

COMMAND PAPERS AND LAW COMMISSION REPORTS

Kenya Human Rights Commission, Labour Rights and Legal Framework in Kenya, 2019
Kituo Cha Sheria, The Kenyan Worker and The Law: An Information Booklet on Labour Law

COMMENTS
Excellent research by the student
Substantively the paper is well mapped
Keep it up

FINAL GRADE 14/15

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