Incomplete updated Version :- I Erick Mango charge President Uhuru Kenyatta and ex-Premier Raila Odinga with co-conspirators including two OCSs at Migori Police Station, ex-Chief Amara, current Chief Onyango of Suna East Migori, AP Police Owino, Peter Mango, Pamela Mango and others pawns on the ground as listed on the statement below with Criminal-Conspiracies to defeat justice and interfere with witnesses, commit misdemeanors, felonies including defilement and murder contrary to Sections 117, 393, 395, 157, 224; These charged together with "A Series of Sexual-Crimes" contrary to the Sexual-Offenses Act Cap.63 Articles 162 (c), 165, 2 (4), 23 (3) (d), 145 (1), 144 (1) (3), 5, 12, 20 (1 ) (2), including indecent-acts / assaults as regards incestuous-and-homosexual harassments Penal-Code CoK-2010:- [ I urge the CJ in accordance with the edict in Article 10 CoK-2010 to exercise her powers under Article 161 (2) (a) as read together with provisions of the Rules of Court Section 2 (1) regarding the National Policy Guideline on the Administration of the SOA.

I Erick Mango charge President Uhuru Kenyatta and ex-Premier Raila Odinga with co-conspirators including two OCSs at Migori Police Station, ex-Chief Amara, current Chief Onyango of Suna East Migori, AP Police Owino, Peter Mango, Pamela Mango and others pawns on the ground as listed on the statement below with Criminal-Conspiracies to defeat justice and interfere with witnesses, commit misdemeanors, felonies including defilement and murder contrary to Sections 117, 393, 395, 157, 224; These charged together with "A Series of Sexual-Crimes" contrary to the Sexual-Offenses Act Cap.63 Articles 162 (c), 165, 2 (4), 23 (3) (d), 145 (1), 144 (1) (3), 5, 12, 20 (1 ) (2), including indecent-acts / assaults as regards incestuous-and-homosexual harassments Penal-Code CoK-2010:- [ I urge the CJ in accordance with the edict in Article 10 CoK-2010 to exercise her powers under Article 161 (2) (a) as read together with provisions of the Rules of Court Section 2 (1) regarding the National Policy Guideline on the Administration of the SOA.

Introduction

[1.]:- The latest turn of events has been brought forth by a conspiratorial pattern of continuous violations of the law by the mentioned accused in the title notice-of-motion above concerning a repeated series-of-crimes in which the most recent happened on the 5th of August 2021 for which went to  formally file the  complaints after drafting on Saturday  the 7^th August 2021 at Migori Police Station at a snail's pace cause of the exhausting extreme hunger-torture ritual-cycles I was still recovering from; and where the Front-Desk told me to go to the crimes office who directed me to return on the morrow [ 8/08/2021 ] cause of renovations that were taking place.      

[2.]:- The amicable OCS on Sunday the 8^th August 2021 [ a different one ] smartly dressed in a suit and hat told me to present my case the following day with the ODPP Migori cause of the complex, interconnected, conspiratorial nature of my case touching on the President Uhuru and ex-Premier Raila. At first he'd asked me to report as formally with the 'report desk' which I told him was the one that had sent me there. So he lent me an ear as I briefed him on the criminal conspiracy & sex crime charges' various counts of each before suggesting midway I present my case to the DCI the following Monday; but then my file caught his sight and he inquired of the contents for which I opened it for his perusal presenting him with different files chronicling the 14+ OBs interconnecting with the criminal conspiracies of which I updated him the more as he perused. That's when he finally told me the conspiratorial nature of my case was complex since it touches on Uhuru and Raila and thus directed that I present the same to the ODPP Migori on the morrow.

[3.]:- It took a while as I prepared waiting to go present my case to the ODPP Migori cause ICC-Indicted mass-murderer Uhuru by proxy of his 'Brookside Dairy Jacket' paid-pawn witches [ defendants Pamela and Peter Mango ] still tried to sabotage my submissions of evidence with them  taking breakfast and leaving for town while I’d to guess on my first ration { as if I'd asked to come to their abode }; Thus did the defendant parties exploit  the hunger-torture starvations cyclic-rituals to wonna obstruct my presentation of the facts and evidence of the case.

[4.]:- I finally made it to the ODPP Migori on Tuesday  10^th August 2021 where the Secretariat after preliminaries led me to the Prosecution Counsel whom I briefed adequately also regarding my charges of criminal conspiracies and criminal sexual conducts both on numerous counts and incriminating President Uhuru  and ex-Premier Raila  as Chief-defendants / architects among adversely mentioned co-conspirator accomplices and others. The lady Prosecution Counsel told me they deal with printed submissions / complaints and advised me to print-out the soft copies I'd relayed to civil society groups including the legal fraternity then submit the same to her. I asked for more time due to wanting resources which could be elusive since I would’ve to flash friends and well-wishers for soft loans / spare cash to bullet and print-out the soft copies.

[5.]:- Fast rewind to June 2012 where I was wrongfully and unlawfully arrested,  detained,  prosecuted,  jailed & relocated / evicted / transported  to Migori by Uhuru’s Mombasa Municipal Council police conveniently-animistically called Ikenya plus Swaleh and another third one violating my rights to liberty.

[6.]:-  Plaintiff / Complainant

Independent professional:- Analytical-theoretical researcher / Public lecturer and Private medical-geneticist contractor / Counselor ; French Tour Guide, Teacher, Translator ; SMM / VA ; Freelance science writer & blogger ; Podcaster for audio & video shows including pay-TV subscriptions ; Affiliate marketer ; 

Founder / Director : Les Misérables Activists Advocacy and Consultants ; 

Defendants

[7.]:- The first defendant’s the President of Kenya and C-in-C of the KDF President Uhuru Kenyatta whom I

           together  with ;    

[8.]:- The second defendant ex-Premier Raila Odinga ;  and

[9.]:- The third defendant Peter Mango ; { the plaintiff’s alleged father pending estrangement proceedings } plus

            his wife below ;

[10.]:-  The fourth defendant Pamela Mango ; I charge all { i.e. defendants nos. 6-9 }

                       {a.}- Criminal-Conspiracies to defeat justice and interfere with witnesses,

                                   Commit misdemeanors and felonies including murder and defilement as

                                   regards sodomy contrary to Sections 117, 393, 395, 157, 224 of the Penal

                                    Code; as read together with

                      {b.}-  "A Series of Sexual-Crimes" contrary to the Sexual-Offenses Act Cap.63

                                     Articles 162 (c), 165, 2 (4), 23 (3) (d), 145 (1), 144 (1) (3), 5, 12, 20 (1 ) (2),

                                      including indecent-acts / assaults as regards incest and homosexual-

                                      harassments Penal-Code CoK-2010;                                 

                       {c.}- Witchcraft contrary to Section 2 of the Witchcraft Act Cap. 67 

 [11.]:- The fifth defendants are 3 Mombasa Municipal Council Police including Ikenya, Swaleh and another

               Whom all three I charge with :-

                        {a.}:-  Wrongful and unlawful arrest, detention, prosecution, jail, & bail ; while
                        {b.}:- For Ikenya additionally I charge him with forced relocation / eviction / transportation  to         
                                  Migori plus

                                  {b1.}:- Criminal-Conspiracies to defeat justice and interfere with witnesses,

                                              Commit misdemeanors and felonies including murder and defilement as

                                              regards sodomy contrary to Sections 117, 393, 395, 157, 224 of the Penal

 

                                                 Code; as read together with ; 

                                   {b2.}:- "A Series of Sexual-Crimes" contrary to the Sexual-Offenses Act Cap.63

                                                  Articles 162 (c), 165, 2 (4), 23 (3) (d), 145 (1), 144 (1) (3), 5, 12, 20 (1 ) (2),

                                                  including indecent-acts / assaults as regards incest and homosexual-

                                                   harassments Penal-Code CoK-2010;  and

                                    {b3.}:-  Witchcraft contrary to Section 2 of the Witchcraft Act Cap. 67 

 [12.]:- The sixth defendant’s OCS-1 ; 

 [13.]:- The seventh defendant’s OCS-2 ;

 [14]:- The eighth defendant’s ex-Chief Amara of Suna East Migori  ;

 [15]:- The ninth defendant’s current Chief Onyango of Suna East Migori  ;

 [16.]:-The tenth defendant’s Administration Police Owino of Chamkombe Kakrao ;

            all whom { i.e. defendants no. 12-16 }  I charge with :-

                         {a}:- Criminal-Conspiracies to defeat justice and interfere with witnesses,

                                  Commit misdemeanors and felonies including murder and defilement as

                                  regards sodomy contrary to Sections 117, 393, 395, 157, 224 of the Penal

                                   Code; as read together with,

                         {b.}:- "A Series of Sexual-Crimes" contrary to the Sexual-Offenses Act Cap.63

                                     Articles 162 (c), 165, 2 (4), 23 (3) (d), 145 (1), 144 (1) (3), 5, 12, 20 (1 ) (2),

                                     including indecent-acts / assaults as regards incest and homosexual-

                                     harassments Penal-Code CoK-2010;

[17.]:- The eleventh defendants are the Mombasa 'JomvuuKuu GoK fire-arm licensed Benz witchdoctor Omar'

             Plus the two policemen in uniform whom I charge with :-

                       {a.}:- Abduction and enforced-disappearance contrary to Article 258 Cap. 63 ;  and

                       {b.}:- Witchcraft contrary to Section 2 of the Witchcraft Act Cap. 67 

[18.]:- The twelfth defendants are brothers Paul Mango and Joseph Olala whom I charge with :-

                       [a.]:- Criminal-Conspiracies to defeat justice and interfere with witnesses,

                                  Commit misdemeanors and felonies including murder 

                                  contrary to Sections 117, 393, 395, 157, 224 of the Penal

                                   Code; as read together with,

                       [b.]:- Threat to life contrary to Section 223 (1) of the Penal Code ; and

                       [c.]:-  Attempted human-trafficking contrary to the 'Counter-Trafficking in Persons Act' No. 8 of

                                 2010   Cap. 61 CoK-2010 and the UN Convention Against Organized Crime supplemented by

                                the  'Palermo Protocol' 

[19.]:- The thirteenth defendants are the alleged GoK GSU on-leave of Bell's Pub attack, his eight-or-so bouncers / attendants of Bell's Pub, and accomplices Engineer Emmanuel Edgar Sirma, Engineer Benjamin Anambo who together with ex-Chief Amara and/or Odira I charge with :-

                       [a.]:-  Criminal-Conspiracies to defeat justice and interfere with witnesses,

                                  Commit misdemeanors and felonies including murder 

                                  contrary to Sections 117, 393, 395, 157, 224 of the Penal

                                  Code; 

                       [b.]:- Attempted robbery with violence contrary to Section 296 (2) of the Penal Code

Submissions

[20.]:-                    In "Republic v. Chief Justice  of Kenya & 6 others Ex-parte Moijo Mataiya Ole Kewua            {2010}  and Nyarotho vs. Attorney General & 3 others [2013],' the High Court of Kenya held that a Sitting President can be sued in his  official capacity for constitutional and legal transgressions; while in 

                             "David Ndii & others v. Attorney General and others" aka  the BBI Case, the BBI judgement held that a sitting president could be sued in his personal capacity for violating the constitution and the law contrary to Articles 143 (1) & (2) governing criminal and civil proceedings against the State President. 

                          Thus the President doesn't enjoy absolute immunity relying on Article 259 to give Article 143 (2) a wider interpretation. Hence the  constitutional provisions protecting the President from legal proceedings are against public policy when it's used in a manner likely to affect the interest of an individual or issues concerning human rights [ Article 25 and 48 ] and environmental protection meant for the greater public good. 

                          I urge the CJ to use this jurisdiction to summon the President at Migori Police Station. I pray  the CJ to exercise her powers in alignment with the rule of law consistently with the CoK-2010 and in effect allow me to access justice and the right to a fair hearing. I urge the CJ to invoke her powers as President of the Supreme Court to secure my rights to due process and the course of justice for expeditious determinations before a competent law courts basing on intelligent  conviction and not passions, beliefs or political masses. I pray the CJ makes cogent and all-encompassing Rules of Court for the implementation of the Sexual Offenses Act Section 47A effectively to address gray areas, lacuna and challenges; as well as to ensure respects for the rights and dignity of the victim / survivors essential to achieving justice and checking that justice is seen to be done.

[21]:-                         Civil remedies can't bar the filing of criminal charges cause one set of facts can be the foundation of a criminal charge & the basis for a civil action as is expressly contemplated by Statute in Section 193A of the Criminal Procedure Code titled "Concurrent Criminal and Civil Proceedings" which states that: 'Notwithstanding the provisions of  any other written law, the fact that any matter in issue in any criminal proceedings is also directly or substantially an issue in any pending civil proceedings and thus shall not be a ground for any stay, prohibition or delay of the criminal proceedings.

[22.]:- My 'socio-economic medico-legal' arrested-development dehumanization's endless-persecution by Uhuru-&-Raila's Jinn-Theocracy GoK including imposed pennilessness-pauperism 3D-'pasive male'-existence below the poverty line; cyclic-ritual hunger-torture starvations; rape of conscience; mandatory systems of commitment; gas-lighting and a psychiatric-system abuse approach including a threatening cycle-pattern of enforced disappearance by abductions for gross infringement violations of my constitutional protections and rights, committed and still being committed on my person, psychology and

life has its genesis on the Chief-defendants Uhuru & Raila's psychopathological, primitive, retrogressive,
prehistoric-descendant-culture faith-belief in the world of witchcraft, sorcery, animism, voodoo, jinns, contagion, spiritualism superstitions as demonstrated in this {link}. Thus have the occultists unleashed an exorcise-mission designed to ultimately end in my cold death murder as has been proclaimed by ex-Chief Amara of Suna East Migori Kakrao { that they'll execute the same through all means either by rat-poisoning or a machete-hacking gang } and as was fronted by their witchdoctors supervised by their respective bodyguards / mouth-pieces including Raila's personal bodyguard introduced by the JK witchdoctor Omar & Uhuru's animist witch-hunter MMC cop Ikenya { a career bodyguard } with the Migori witchdoctor; scenarios which have resulted in this arrested-development

Particulars of The Offences / Charges

Supporting Links

https://erick-mango.blogspot.com/2013/06/the-law-prosecuting-raila-ex-treason_6.html

[ https://erick-mango.blogspot.com/2013/09/prosecuting-raila-ex-treason-convict.html
[ https://erick-mango.blogspot.com/2019/09/fwd-outlawing-outcasting-kutolewa-golo.html
[ Kenyatta avenue assassination ]
https://erick-mango.blogspot.com/2013/04/the-law-prosecuting-raila-ex-treason_26
[ Ikenya Migori Police Station OB ]
https://erick-mango.blogspot.com/2020/03/httpswwwamazoncomgproductb083wkjzp4_6.html
[False Imprisonment ]
https://erick-mango.blogspot.com/2016/05/prosecuting-raila-ex-treason-convict_24.html
[ Accident Profile ]
https://erick-mango.blogspot.com/2019/08/i-dont-need-uhurus-jinn-theocracy-gok.html
[ https://erick-mango.blogspot.com/2013/06/the-law-prosecuting-raila-ex-treason.html
[ https://erick-mango.com/2013/06/the-law.html 

[https://erick-mango.blogspot.com/2014/12/prosecuting-raila-ex-treason-convict_31.html
[ https://erick-mango.blogspot.com/2014/06/prosecuting-raila-ex-treason-convict_18.html
[ https://erick-mango.blogspot.com/2013/06/the-law-prosecuting-raila-ex-treason_21.html
[ https://erick-mango.blogspot.com/2014/02/prosecuting-railaex-treason-convict-and.html
[ https://erick-mango.blogspot.com/2013/05/the-law-prosecuting-raila-ex-treason_6.html