88 • • for those who wished to have a say on the issue to do so. The legislature would then be required to take into considerations the views expressed by the public but it was not bound to implement the views. The legislature was not required to conduct a census-like exercise of knocking on the door of every citizen in its jurisdiction in order to extract an opinion. Time available for public participation had to be considered in light of all the stages of the legislative process. The public was aware of the Bill, from April 10, 2018, when it was published and could have participated from that date. The purpose of publishing a Bill was to notify the public and invite representation through elected representatives or direct submission of memoranda or petitions. Even though the newspaper advertisement inviting members of the public to make representations on the Bill was made on May 7, 2018, it was not correct to say that the public only had seven days to participate in the legislative process as the impugned amendment was to be discussed before the Administration and National Security Committee of the National Assembly. The public could participate in the committee hearing even after the expiry of the period advertised. In introducing the Statute Law (Miscellaneous Amendments) Bill 2018, the legislature intended to undertake amendments on certain statutes without referring to them as minor amendments. There was sufficient time availed to the public to give views about the amendments and therefore there was sufficient public participation. On the omnibus bill, the court held that the use of omnibus bills to effect substantive amendments had its shortcomings and such a process generally limited the right of the people to participate in the passing of laws. Several proposed amendments to assorted statutes relating to different activities, when introduced together would not receive the kind of attention that they should if they were placed in stand-alone bills. The risk of excluding the public from participating in the legislative process was exacerbated if a short period for submitting views was provided. If there was evidence demonstrating that public participation requirements were complied with in the adoption of the amendments, the court should not be quick to invalidate the amendments simply because an omnibus Bill was used to make the amendments. It was not the place of the courts to dictate the procedures to be used by the two houses of Parliament in executing their legislative mandate. The court was confined to determining whether legislative bodies had complied with the Constitution and the law in delivering on their mandates.There was evidence of sufficient time given for public participation. The stakeholder engagement on the omnibus Bill before various committees facilitated public participation. The use of the omnibus Bill to enact the impugned legislation was not unconstitutional. On legislative process and the role of the Senate, the court held that the jurisdiction of the Senate did not extend to all legislation passed by the National Assembly. It was difficult to think of any legislation that did not touch on counties. The Fourth Schedule to the Constitution gave a wide array of functions to the counties. The functions, however, did not include a national population register. The impugned CITIZENSHIP AND NATIONALITY RIGHTS CASE DIGEST