1. IEBC did not tally and verify the count before declaring the winner
  2. IEBC was dysfunctional and disunited and failed to deliver elections as an independent, transparent and impartial body as required in law
  3. The results of constituencies which they claim IEBC did not tally and verify before the final declaration affected the final outcome.
  4. The IEBC declaration did not follow the law and is therefore unconstitutional, invalid, null and void.
  5. Ruto did not meet and/or attain the constitutional threshold of 50 per cent plus 1 of the votes cast
  6. There were elaborate and fraudulent premeditated schemes to interfere with and undermine and defeat the integrity, credibility and security of the presidential election
  7. There was deliberate interference with the integrity, credibility and security of the presidential election with direct knowledge and participation of Chebukati.
  8. There was deliberate interference with the presidential elections and this altered the outcome.
  9. Chebukati fraudulently manipulated and distorted presidential election results to declare an inaccurate and invalid outcome.
  10. The irregularities and errors in the presidential elections were not minor or administrative or occasioned by human imperfection.
  11. Chebukati was a rogue chairperson and conducted a presidential election with premeditated intent and objectives of subverting and undermining the integrity of the electoral process.
  12. Some of the Forms 34A that were transmitted into the IEBC portal are different, in substance and form, from the physical copies issued to Raila’s agents
  13. IEBC system was corruptly manipulated to the extent that the result on forms 34As is incomplete and provides an inaccurate number of total votes cast
  14. IEBC system was not secure and third parties gained access and manipulated the results.
  15. There was systemic voter suppression and ballot stuffing in Raila’s strongholds.
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