in my affidavit and are also addressed in the statistical report attached) but does
not change the outcome of the election.
45.6. The computation by the applicant, based on a turnout of 72%, does not,
therefore, yield a correct result reflective of what happened on election day.
45.7. The 700 000 votes that the applicant alleges are unaccounted for are directly
resultant upon the use of 72% as the final voter turnout in the presidential
election and not the correct 85.1%.
45.8. Further, the figure that the applicant comes up with, 4 032 000, as 72% of the
total voter population includes, by necessary implication, every vote that would
be cast in a presidential poll including votes that would, on the count, be deemed
to be invalid for one reason or another. The figures he indicates as the total votes
cast from the announced results, 4 775 640, and from the data on the Electoral
Commission’s CD, 4 774 878, both reflect the total valid votes cast in terms of
the announcements and the data on the CD.
45.9. The 4 032 000 on the one hand and the 4 775 640 and 4 774 878 on the other
are thus totals representing two different kinds of things the former including
every valid and invalid vote and the latter only the valid votes. The applicant then
proceeds to subtract, in turn, the two elements of the latter category of votes
from the former category of votes thus yielding in each instance the 700 000
alleged unaccounted votes without taking account, in that computation, of the
difference between the two things he has subtracted from each other.
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