REPUBLIC OF KENYA

IN THE HIGH COURT OF KENYA AT MOMBASA

CONSTITUTIONAL & HUMAN RIGHTS DIVISION

PETITION NO. OF 2022

IN THE MATTER OF: CONTRAVENTION ARTICLE 19(2), 21, 22,23 AND 24 OF THE

CONSTITUTION OF KENYA

AND

IN THE MATTER OF: AN ALLEGED CONTRAVENTION OF FUNDAMENTAL

RIGHTS AND FREEDOMS UNDER ARTICLES 6,10, 24, 28, 42,43,47,55,69,70,174,186

OF THE CONSTITUTION OF KENYA

AND

IN THE MATTER OF: THE CONSTITUTION OF KENYA (PROTECTION OF

RIGHTS AND FUNDAMENTAL FREEDOMS) PRACTICE AND PROCEDURE

RULES,2013

AND

IN THE MATTER OF: THE ENVIRONMENTAL MANAGEMENT AND CO-

ORDINATION ACT CAP 387 OF THE LAWS OF KENYA,

-BETWEEN-

MAJALIWA…………………………………………………………..….1ST PETITIONER

COUNTY GOVERNMENT OF MOMBASA……………………….....2ND PETITIONER

KENYA DOCK WORKERS UNION…………………………………..3RD PETITIONER

KENYA TRANSPORTERS UNION…………………...………..…….4TH PETITIONER

-VERSUS-
 THE ATTORNEY GENERAL………………………………………….1ST RESPONDENT

KENYA PORTS AUTHORITY…………………………………………2ND RESPONDENT

KENYA RAILWAYS CORPORATION……………………………….3RD RESPONDENT

PETITION

TO: THE HONOURABLE HIGH COURT OF KENYA

AT MOMBASA

THE HUMBLE PETITION OF MAJALIWA, COUNTY GOVERNMENT OF MOMBASA,

KENYA DOCK WORKERS UNION AND KENYA TRANSPORTERS UNION WHOSE

ADDRESS OF SERVICE FOR PURPOSES OF THIS PETITION ONLY, IS CARE OF FIRM

13 & ASSOCIATES, KARIANDUSI PLAZA, 5TH FLOOR, KIMEU ROAD, NAIROBI

STATES AS FOLLOWS: -

A. JURISDICTION

The Petitioners brings this Petition under the provisions of Article………………… of the

Constitution of Kenya and thus this Honourable Court has jurisdiction.

The relief(s) sought cannot be granted by any other body/ institution established by the

law except this Honourable court.

B. DESCRIPTION OF PARTIES

1. The 1st Petitioner is an adult male of sound mind residing and working for gain in

Mombasa County within the Republic of Kenya. He has filed this Petition on his own

behalf as a person whose rights and enjoyment thereof have been violated and/or are

threatened by the violation of the provisions of the law forming the subject matter of this

Petition. His address for the purposes of this petition shall be FIRM 13 & COMPANY
 ADVOCATES, KARIANDUSI PLAZA, 5TH FLOOR, KIMEU ROAD, P.O BOX

555, NAIROBI.

2. The 2nd Petitioner is a County established under Article 6(1) of the Constitution of Kenya,

2010 and listed as County number 1 in the First Schedule thereto. The petitioner’s

address of service for the purposes of this petition shall be care of FIRM 13 &

COMPANY ADVOCATES, KARIANDUSI PLAZA, 5TH FLOOR, KIMEU ROAD,

P.O. BOX 555, NAIROBI.

3. The 3rd Petitioner is a trade union in Kenya that promotes and protects the rights and

interests of the working class in the in the shipping and docking industry. The petitioner’s

address of service for the purposes of this petition shall be in the care of FIRM 13 &

COMPANY ADVOCATES, KARIANDUSI PLAZA, 5TH FLOOR, KIMEU ROAD,

P.O.BOX 555, NAIROBI.

4. The 4th Petitioner is a trade union in Kenya that promotes and protects the rights and

interests of the working class in the transport industry. The petitioner’s address of service

for the purpose of this petition shall be in the care of FIRM 13 & COMPANY

ADVOCATES, KARIANDUSI PLAZA, 5TH FLOOR, KIMEU ROAD, NAIROBI.

5. The 1st Respondent is the Office of the Attorney General and is established under Article

156 of the Constitution of Kenya and the Office of the Attorney General Act. Among

other mandates, the Office of Attorney General represents national government in legal

proceedings except criminal proceedings. Its address of service is SHERIA HOUSE,

HARAMBEE AVENUE, P.O. BOX 40112-00100, NAIROBI.

6. The 2nd Respondent, Kenya Ports Authority, is a state corporation established under the

Kenya Ports Authority Act ,and whose mandate is to "maintain, operate, improve and

regulate all scheduled seaports" on the Indian Ocean coastline of Kenya. Its address of

service is P.O. BOX 95009-80104 MOMBASA. Email: ca@kpa.co.ke Tel: +254-41-

2112999.

7. The 3rd Respondent is the Kenya Railway Corporation is a state corporation established

under the Kenya Railways Corporation Act whose address of service is WORKSHOPS

ROAD, OFF HAILE SELASSIE AVENUE, NAIROBI. Email: info@krc.co.ke Tel:

0790-388-887.

C. THE CONSTITUTIONAL FOUNDATIONS OF THE PETITION

8. Article 2(1) of the Constitution of Kenya provides that it is the supreme law of the land

and binds all state organs at both levels of government. The petitioner avers that the

respondents violated this provision by entering into the illegal contract that the violates

the constitutional rights of the petitioners and the people of Mombasa.

9. Article 3 of the Constitution places an obligation on every Kenyan citizen to defend the

constitution. The respondents have failed in their mandate as Kenyan citizens and public

officers to respect, uphold and defend the Constitution by being in contravention of its

provisions.

10. Article 10 of the Constitution of Kenya establishes the National Values and Principles of

Governance. which binds all state organs, state officers, public officers and all persons

and to implement its provisions for the benefit of all Kenyans. The respondents have

acted in contravention of this provision by executing this project without proper public

participation.
11. Chapter 4 of the Constitution of Kenya guarantees and protects the fundamental rights

and freedoms of every Kenyan citizen. These freedoms and protections are for the

preservation of human dignity, promotion of social justice and the realization of the

potential of all Kenyan citizens. The respondents’ actions are in violation of the said

provisions.

12. Article 42 of the Constitution guarantees every citizen the right to a clean and healthy

environment. This extends to the right to: -

a) To have the environment protected for the benefit of present and future

generations through legislative and other measures, particularly those

contemplated in Article 69; and

b) To have obligations relating to the environment fulfilled under Article 70.

13. Article 69(1)(g) of the Constitution mandates the state to eliminate processes and

activities that are likely to endanger the environment.

14. Article 70(1) of the Constitution outlines the procedure with respect to enforcement of

environmental rights and further provides for various legal remedies that are available to

redress any right that has or is likely to be denied, violated, infringed or threatened.

Article 70 (1) “If a person alleges that a right to clean and healthy environment

recognized and protected under Article 42 has been, is being or is likely to be denied,

violated, infringed or threatened, the person may apply to a court for redress in

addition to any other legal remedies that are available in respect to the same matter”.

Article 70(2) “On application under clause (1), the court may make any orders, or

gives any directions, it considers appropriate-

 a) To prevent, stop or discontinue any act or omission that is harmful to the

environment;

b) To compel any public officer to take measures to prevent or discontinue any act

or omission that is harmful to the environment; or

c) To provide compensation for any victim of a violation of the right to a clean

and healthy environment.

Article 70 (3) “For the purposes of this Article, an applicant does not have to

demonstrate that any person has incurred loss or suffered injury.

10. The Petitioner further relies on Section 3(3) of The Environmental Management and

Coordination Act no. 8 of 1999 which further guarantees its right to petition this honorable

court for orders towards redress of any infringement.

Section 3(3) “If a person alleges that the entitlement conferred under subsection (1)

has been, is being or is likely to be contravened in relation to him, then without

prejudice to any other action with respect to the same matter which is lawfully

available, that person may apply to the High Court for redress and the High Court

may make such orders, issue such writs or give such directions as it may deem

appropriate to: -

(a) prevent, stop or discontinue any act or omission deleterious to

the environment;

(b) compel any public officer to take measures to prevent or discontinue

any act or omission deleterious to the environment;

(c) require that any on-going activity be subjected to an environment

audit in accordance with the provisions of this Act;

 (d) compel the persons responsible for the environmental degradation

to restore the degraded environment as far as practicable to its immediate

condition prior to the damage; and

(e) provide compensation for any victim of pollution and the cost of

beneficial uses lost as a result of an act of pollution and other losses that

are connected with or incidental to the foregoing.

11. In light of the above-mentioned provisions of law, the respondent’s actions have breached

Articles 42,43, 69 as read together with Article 70 by failing to protect the environment as

provided for under the Environmental and Coordination Act.

D. ISSUES FOR DETERMINATION

For the foregoing reasons, the Petitioners asks this Honorable court to determine: -

a) Whether the agreement between the Kenya Ports Authority (KPA) and the Kenya

Railways Corporation was in violation of the right to fair administrative action.

b) Whether the agreement violates the socio-economic rights and fundamental rights

of the people of Mombasa

E. REASONS WHEREFORE YOUR PETITIONER HUMBLY PRAYS FOR

REDRESS AS FOLLOWS: -

i. A declaration that the agreement entered into at about 30 th September 2014, is in violation of

Articles 1, 2(4), 10, 21, 22, 23, 43, 46, 47 & 174 of the Constitution of Kenya, 2010.

ii. A declaration that the agreement entered into on or about the 30 th September 2014, between

the 2nd and 3rd Respondents threaten and/ or contravene the right to fair administrative action

of the petitioners and people of the County of Mombasa under Article 47 of the Constitution.
 iii. A declaration that the agreement into at about 30 th September 2014, between the 2nd and 3rd

Respondents threatens and/or contravenes the social and economic rights of the Petitioners

and the residents of Mombasa County under Article 43 of the Constitution.

iv. An order that the 2nd Respondent’s administrative decision requiring consigners, consignees,

clearing and forwarding agents and owners of goods to deliver and collect freight and cargo

from the 3rd Respondent’s Embakasi Inland Container Depot (ICD) contravenes the social

and economic rights of the residents and Mombasa business community and is thus

unconstitutional.

v. A declaration that the 3rd Respondent’s operations at its Embakasi ICD and any other ICD

threatens and contravenes the social economic rights of the residents of Mombasa under

Article 43 of the Constitution and is thus unconstitutional.

vi. An order of mandamus that the Respondents compensate the affected persons for their loss of

livelihood immediately.

vii. Permanent conservatory orders to compel the 2 nd Respondent to shut down polluters and to

treat their waste before disposing it into the Indian Ocean and to desist from air pollution.

viii. Conservatory orders to compel the Respondents to adopt the precautionary principle in

environmental management with respect to preventing the air and water pollution in

Mombasa County caused as a result of their activities.

ix. An order for costs of the Petition.

x. Such other reliefs or orders as this honourable court may deem fit to grant.

DATED at MOMBASA this ………………. day of ……………………………………….2022

FIRM 13 & CO. ADVOCATES LLP

ADVOCATES FOR THE PETITIONERS

DRAWN AND FILED BY: -

FIRM 13 & ASSOCIATES,

KARIANDUSI PLAZA, 5TH FLOOR,

KIMEU ROAD,

P.O.BOX 555,
NAIROBI.

TO BE SERVED UPON

1. OFFICE OF THE ATTORNEY GENERAL

SHERIA HOUSE, HARAMBEE AVENUE,

P.O BOX 40112-00100,

NAIROBI.

TEL: 020-22274619

2. MANAGING DIRECTOR,
KENYA PORTS AUTHORITY,
KILINDINI HARBOUR, MBARAKI LANE,
P.O BOX 95009-80104,
NAIROBI.

3. MANAGING DIRECTOR,
KENYA RAILWAYS CORPORATION,
WORKSHOPS ROAD, OFF HAILE SELASSIE AVENUE,
P.O BOX 30121-0100,
NAIROBI.
 REPUBLIC OF KENYA

IN THE HIGH COURT OF KENYA AT MOMBASA

CONSTITUTIONAL & HUMAN RIGHTS DIVISION

PETITION NO. OF 2022

IN THE MATTER OF: CONTRAVENTION ARTICLE 19(2), 21, 22,23 AND 24 OF THE

CONSTITUTION OF KENYA

AND

IN THE MATTER OF: AN ALLEGED CONTRAVENTION OF FUNDAMENTAL

RIGHTS AND FREEDOMS UNDER ARTICLES 6,10, 24, 28, 42,43,47,55,69,70,174,186

OF THE CONSTITUTION OF KENYA

AND

IN THE MATTER OF: THE CONSTITUTION OF KENYA (PROTECTION OF

RIGHTS AND FUNDAMENTAL FREEDOMS) PRACTICE AND PROCEDURE

RULES,2013

AND
 IN THE MATTER OF: THE ENVIRONMENTAL MANAGEMENT AND CO-

ORDINATION ACT CAP 387 OF THE LAWS OF KENYA,

-BETWEEN-

MAJALIWA…………………………………………………………...….1ST PETITIONER

COUNTY GOVERNMENT OF MOMBASA………………………......2ND PETITIONER

KENYA DOCK WORKERS UNION…………………………………...3RD PETITIONER

KENYA TRANSPORTERS UNION…………………...………...…….4TH PETITIONER

-VERSUS-

THE ATTORNEY GENERAL………………………………………….1ST RESPONDENT

KENYA PORTS AUTHORITY…………………………………………2ND RESPONDENT

KENYA RAILWAYS CORPORATION……………………………….3RD RESPONDENT

SUPPORTING AFFIDAVIT

I, MAJALIWA, of P.O. Box No. ……………… within the Republic of Kenya make oath and

state as follows: -

1) THAT I am a Marine Eco business expert and a person from the Mijikenda community

resident in Mombasa County.

2) THAT I am fully conversant with the matters in issue herein and therefore competent to

swear this affidavit.

3) THAT I have grown up and studied in Mombasa and currently hold the office of advisor

to the Governor of Mombasa County on social-economic empowerment.

4) THAT for the period of my residency, the community has heavily relied on the port of

Mombasa for employment opportunities.

 5) THAT the agreement entered into by the 2 nd and 3rd Respondent has led to the loss of

income for the residents of Mombasa who have heavily relied on the port economically.

6) THAT the respondents have compromised the residents’ right to a clean environment by

polluting the ocean from their activities.

7) THAT it is in the interest of justice that this petition be heard and determined.

8) THAT no prejudice will be occasioned to the Respondents.

9) THAT I swear this affidavit in support of the instant application seeking the court to

allow the Applicants to be heard urgently.

10) THAT what is deponed here is true to the best of my knowledge and belief.

DRAWN AND FILED BY: -

FIRM 13 & ASSOCIATES,

KARIANDUSI PLAZA, 5TH FLOOR,

KIMEU ROAD,

P.O.BOX 555,
NAIROBI.

TO BE SERVED UPON

1. OFFICE OF THE ATTORNEY GENERAL

SHERIA HOUSE, HARAMBEE AVENUE,

P.O BOX 40112-00100,

NAIROBI.

TEL: 020-22274619

2. MANAGING DIRECTOR,
KENYA PORTS AUTHORITY,
KILINDINI HARBOUR, MBARAKI LANE,
P.O BOX 95009-80104,
 NAIROBI.

3. MANAGING DIRECTOR,
KENYA RAILWAYS CORPORATION,
WORKSHOPS ROAD, OFF HAILE SELASSIE AVENUE,
P.O BOX 30121-0100,
NAIROBI.

REPUBLIC OF KENYA

IN THE HIGH COURT OF KENYA AT MOMBASA

CONSTITUTIONAL & HUMAN RIGHTS DIVISION

PETITION NO. OF 2022

MAJALIWA…………………………………………………………...….1ST PETITIONER

COUNTY GOVERNMENT OF MOMBASA……………………….....2ND PETITIONER

KENYA DOCK WORKERS UNION…………………………………..3RD PETITIONER

KENYA TRANSPORTERS UNION…………………...………..…….4TH PETITIONER

-VERSUS-

THE ATTORNEY GENERAL………………………………………….1ST RESPONDENT

 KENYA PORTS AUTHORITY…………………………………………2ND RESPONDENT

KENYA RAILWAYS CORPORATION……………………………….3RD RESPONDENT

CERTIFICATE OF URGENCY

I FAITH ADEYA, an Advocate of the High Court of Kenya and practicing as such in the firm

of FIRM 13 & COMPANY ADVOCATES, KARIANDUSI PLAZA, 5 TH FLOOR, KIMEU

ROAD, P.O BOX 555, NAIROBI do certify that this matter is of extreme urgency and should

be brought to the immediate attention of this Honourable Court and be heard ex-parte in the first

instance for the following reasons:-

1. THAT the actions of the respondents have led to the loss of livelihood of the residents of

Mombasa.

2. THAT the residents of Mombasa continue to suffer economically as long as the

agreement between the respondents is still in force.

3. THAT the fundamental rights and freedoms of the residents of Mombasa to a clean and

healthy environment have been compromised as they are the most affected from the

environmental degradation from arising from the operation of the port.

4. THAT the effects of the environmental degradation have led to the loss of marine life

reducing commercial fishing infringing their right to livelihood.

5. THAT the residents of Mombasa should benefit the most from the port’s activities since

they are the greatest victims of environmental degradation.

6. THAT unless the applicants believe that the residents of Mombasa’s fundamental rights

and freedoms to a clean and healthy environment will continue to be compromised as

long as the respondents continue operating outside the scope of the law.
 7. THAT unless this Application is certified urgent the Applicants shall continue to suffer

great prejudice that cannot be compensated by way of damages.

8. THAT it is of extreme urgency that this Honourable Court grants the orders sought by

the applicants in order to uphold the fundamental rights and freedoms of the residents of

Mombasa as enshrined in the Bill of Rights.

DATED at MOMBASA this ………………………… day of ………………………...….2022

FIRM 13 & COMPANY

ADVOCATES FOR THE APPLICANTS

DRAWN & FILED BY

FIRM 13 & ASSOCIATES,

KARIANDUSI PLAZA, 5TH FLOOR,

KIMEU ROAD,

P.O.BOX 555,
NAIROBI.

TO BE SERVED UPON

1. OFFICE OF THE ATTORNEY GENERAL

SHERIA HOUSE, HARAMBEE AVENUE,

P.O BOX 40112-00100,

NAIROBI.

TEL: 020-22274619
 2. MANAGING DIRECTOR,
KENYA PORTS AUTHORITY,
KILINDINI HARBOUR, MBARAKI LANE,
P.O BOX 95009-80104,
NAIROBI.

3. MANAGING DIRECTOR,
KENYA RAILWAYS CORPORATION,
WORKSHOPS ROAD, OFF HAILE SELASSIE AVENUE,
P.O BOX 30121-0100,
NAIROBI.
 REPUBLIC OF KENYA

IN THE HIGH COURT OF KENYA AT MOMBASA

CONSTITUTIONAL & HUMAN RIGHTS DIVISION

PETITION NO. OF 2022

MAJALIWA…………………………………………………………..….1ST PETITIONER

COUNTY GOVERNMENT OF MOMBASA……………………….....2ND PETITIONER

KENYA DOCK WORKERS UNION…………………………………..3RD PETITIONER

KENYA TRANSPORTERS UNION…………………...………..…….4TH PETITIONER

-VERSUS-

THE ATTORNEY GENERAL………………………………………….1ST RESPONDENT

KENYA PORTS AUTHORITY…………………………………………2ND RESPONDENT

KENYA RAILWAYS CORPORATION……………………………….3RD RESPONDENT

NOTICE OF MOTION

(Pursuant to Article 22 (2), 23 (1) & (3), 42, 69, 70 of the Constitution of Kenya, 2010, Section

1A, 1B and 3A of the Civil Procedure Act, Order 40, Order 51 of the Civil Procedure Rule of

2010 and all other enabling provisions of law)

TAKE NOTICE that this Honourable Court will be moved on the ……………... day of ……...

2022 at 9:00 O’clock in the forenoon or soon thereafter as the matter may be called for hearing

on the application of Counsel for the Applicant for the following Orders;

1. THAT this application be certified as of extreme urgency and service thereof be

dispensed with in the first instance and the same be heard ex parte for purposes of

granting Interim Orders.

 2. THAT an interim injunction be issued restraining the Respondents, their agents, servants

and/or employees and anyone claiming through them or under them from spilling hot

steam and oil from the engines or in any other manner whatsoever enhancing

environmental degradation pending the hearing and determination of the Application.

3. THAT an interim injunction be issued restraining the Respondents, their agents, servants

and/or employees and anyone claiming through them or under them from spilling hot

steam and oil from the engines or in any other manner whatsoever enhancing

environmental degradation pending the hearing and determination of the Petition.

4. THAT costs be provided for.

WHICH APPLICATION is based on the grounds:

1. THAT the actions of the respondents offend the sense of justice and propriety as they did

not involve the residents of Mombasa before entering into the agreement.

2. THAT this petition has an overwhelming chance of success.

3. THAT no prejudice will be occasioned to the respondents in this application.

4. THAT it is in the interest of justice that this application be allowed.

FURTHER the application is supported by the annexed affidavit of FAITH ADEYA

dated…………… and on such other and further grounds and reasons as may be adduced at the

hearing hereof.

DATED at MOMBASA this ……………. day of ……………………………….2022

FIRM 13 & COMPANY

ADVOCATES FOR THE APPLICANTS

DRAWN & FILED BY

FIRM 13 & ASSOCIATES,

KARIANDUSI PLAZA, 5TH FLOOR,

KIMEU ROAD,

P.O.BOX 555,
NAIROBI.

TO BE SERVED UPON

1. OFFICE OF THE ATTORNEY GENERAL

SHERIA HOUSE, HARAMBEE AVENUE,

P.O BOX 40112-00100,

NAIROBI.

TEL: 020-22274619

2. MANAGING DIRECTOR,
KENYA PORTS AUTHORITY,
KILINDINI HARBOUR, MBARAKI LANE,
P.O BOX 95009-80104,
NAIROBI.
3. MANAGING DIRECTOR,
KENYA RAILWAYS CORPORATION,
WORKSHOPS ROAD, OFF HAILE SELASSIE AVENUE,
P.O BOX 30121-0100,
NAIROBI.

Note

If any party served does not appear at the time and place above-mentioned such order will be

made and proceedings taken as the court may think just and expedient.
 REPUBLIC OF KENYA

IN THE HIGH COURT OF KENYA AT MOMBASA

CONSTITUTIONAL & HUMAN RIGHTS DIVISION

PETITION NO. OF 2022

MAJALIWA………………………………………………………….….1ST PETITIONER

COUNTY GOVERNMENT OF MOMBASA……………………….....2ND PETITIONER

KENYA DOCK WORKERS UNION…………………………………..3RD PETITIONER

KENYA TRANSPORTERS UNION…………………...………..…….4TH PETITIONER

-VERSUS-

THE ATTORNEY GENERAL………………………………………….1ST RESPONDENT

KENYA PORTS AUTHORITY…………………………………………2ND RESPONDENT

KENYA RAILWAYS CORPORATION……………………………….3RD RESPONDENT

SUPPORTING AFFIDAVIT

I, FAITH ADEYA, of P.O. Box No. ……………… within the Republic of Kenya make oath

and state as follows: -

1. THAT I am the Applicant’s counsel in conduct of the matter herein therefore competent

to swear this affidavit.

2. THAT I am fully conversant with the matters in issue herein and therefore competent to

swear this affidavit.

3. THAT the agreement entered into by the 2 nd and 3rd Respondent has led to the loss of

income for the residents of Mombasa who have heavily relied on the port economically.

4. THAT the respondents have compromised the residents’ right to a clean environment by

polluting the ocean from their activities.

 5. THAT it is in the interest of justice that this petition be heard and determined.

6. THAT no prejudice will be occasioned to the Respondents.

7. THAT I swear this affidavit in support of the instant application seeking the court to

allow the Applicants to be heard urgently.

8. THAT what is deponed here is true to the best of my knowledge and belief.

Sworn at Mombasa this.……………...day of…………………………………………...2022

By the said

…………..

BEFORE ME

COMMISSIONER FOR OATHS

DRAWN AND FILED BY: -

FIRM 13 & ASSOCIATES,

KARIANDUSI PLAZA, 5TH FLOOR,

KIMEU ROAD,

P.O.BOX 555,
NAIROBI.

TO BE SERVED UPON

1. OFFICE OF THE ATTORNEY GENERAL

SHERIA HOUSE, HARAMBEE AVENUE,

P.O BOX 40112-00100,

 NAIROBI.

TEL: 020-22274619

2. MANAGING DIRECTOR,
KENYA PORTS AUTHORITY,
KILINDINI HARBOUR, MBARAKI LANE,
P.O BOX 95009-80104,
NAIROBI.

3. MANAGING DIRECTOR,
KENYA RAILWAYS CORPORATION,
WORKSHOPS ROAD, OFF HAILE SELASSIE AVENUE,
P.O BOX 30121-0100,
NAIROBI.