In June 1923, British settler Jasper Abraham was tried for the murder of African labourer Kitosh in the Kenya Colony. Kitosh had died after a flogging administered by Abraham and his employees at a farm near the town of Molo, Kenya. The jury, which was all-white and composed of Abraham's acquaintances, found him guilty of a lesser charge of "grievous hurt" and he was sentenced to two years' imprisonment.
The sentence, widely regarded as overly lenient, brought condemnation from the British government's Colonial Office regarding the way the case had been handled by the colony's judicial system and the continued use of the Indian Penal Code (IPC) in Kenya, which differed significantly from English law in its treatment of homicide. A succession of British secretaries of state attempted to impose legal reform on the colony, though these were resisted by Chief Justice of Kenya Sir Jacob William Barth and Governor Edward Grigg, 1st Baron Altrincham. The IPC was finally replaced in Kenya with a new legal code in 1930.
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