“Going Back to the Roots”; Resolving Disputes through Alternative Means with a Bias inTraditional Justice SystemsBy:Mwai Samuel MainaP.O Box 611-10101Karatina, Kenya 254724868307, email@example.comMacharia James MuriukiP.O BOX 2882 – 00100Nairobi, Kenya 254722698140, firstname.lastname@example.orgA Paper Submitted To National Council for Law Reporting for PublicationApril, 2021
DECLARATIONWe, Mwai Samuel Maina and Macharia James Muriuki do declare that this is our original workand has not been published or under consideration elsewhere for publication or for any award.The sources we have used or quoted have been indicated and acknowledged by references.Signed .Date 20 April 2021This paper has been submitted to the National Council for Law Reporting for publication withour consent/approvalMwai Samuel Maina and Macharia James Muriukiii
ABSTRACTProper and effective administration of justice plays an important role in addressing disputes thatarises in the society. In our societies, there exist structured and recognised forms of resolvingdisputes. The main method of resolving disputes being formal courts established within the state.Unfortunately in most jurisdictions, there have been challenges facing the formal mechanism thathave made it not accessible to majority of the population. These challenges include costsassociated with litigation, complexity of rules as well as backlog of cases. This has necessitatedstates to adopt and recognise alternative dispute resolution mechanisms. This paper examineshow traditional dispute resolution mechanisms are recognised and can be used in resolvingdisputes arising in the society in an effective and efficient manner. Noting that the Constitutionrequires traditional justice systems to meet certain requirements, this article offers someguidelines in which the same can be implemented. The Constitution of Kenya under Article 159(2) provides that in the administration of justice, court should be guided by principles amongthem being promotion of alternative dispute resolution mechanisms inclusive of traditionaldispute mechanisms. The mechanism was recognised based on the reality that the main form ofadministration of justice in the country have been found to be inadequate in addressing all thejustice concerns of the people. Unfortunately despite the constitutional provision being placedmore than a decade ago, little has been realised in actualising traditional dispute resolutionmechanism in the country. This paper therefore provides a discussion based on traditional justicesystems and offers some recommendations on how the same can be applied in Kenya withinconstitutional ambits. Such recommendations if implemented can contribute in enhancingformulation of laws, policies and specific guidelines that will broaden access to justice throughtraditional dispute resolution.Key words: dispute resolution, access to justice, administration of justice, alternativedispute resolution and traditional justice systemsiii
“Going back to the Roots”; resolving Disputes through Alternative means with a Bias inTraditional Justice SystemsMwai Samuel MainaMacharia James Muriuki1.0 IntroductionDue to competing interests and needs in the society, disagreements arise between differentfactions within the society. Some of these disputes may escalate into violent conflicts if theyare not properly managed.1 In order to enhance peace and orderliness in our societies,different mechanisms are established for resolving such disputes. Notably, in all orderlysocieties there are institutions, organs or bodies established to enhance administration ofjustice. The success or failure of such mechanisms depends on how effective and efficientthey are in responding to the needs of people in resolving disputes.The main form of dispute resolution in Kenya is the court process. Formal court system hasbeen in place since the entry of colonial administration upon the adoption of foreign form ofjustice system. Though the system has existed over the years coupled with a number ofchallenges, it has maintained its formal character in the legal system. Quite a huge proportionof the population has been left out in the formal resolution of disputes. According to JusticeNeeds and Satisfaction Report, more than 90% of the population do not access justice in theformal justice system.2 Such an observation had been noted by the former Chief Justice ofKenya, Willy Mutunga who stated that courts in Kenya have used processes that appear to be“remote and mystical” to the majority of the population, thereby leaving out a hugeproportion in the administration of justice.3 Similar findings were noted by Judiciary ofKenya in its alternative justice systems Reports that estimates about 90% of disputes in thecountry to being resolved through justices outside formal court process.41Uwazie, E. E. (2011). Alternative dispute resolution in Africa: Preventing conflict and enhancingstability (Vol. 16, pp. 1-6). Africa Center for Strategic Studies.2Justice Needs and Satisfaction Report, 2017.3The statement is captured in the speech by the former Chief Justice of Kenya Willy Mutunga on 12 th August2012 when addressing the issue of resorting to alternative dispute resolution mechanisms.4Judiciary of Kenya, Alternative Justice Systems Policy Framework 2020.4
Accessibility and expeditious determination of cases is a central determinant inadministration of justice. Due to the persistent need for efficient and effective administrationof justice, there has been awakened spirit to use and recognise alternatives means of disputeresolution. Partly, this has been through recognition and use of traditional justice systems(TJS).1.1 Access to Justice and Administration of justiceAccess to justice is the means by which an aggrieved party resorts to the avenue available forthe resolution of a dispute. According to Cappelleti and Grath, an efficient justice system iswhere access to justice “.is equally accessible to all, and leads to results that areindividually and socially just.”5Access to justice is a fundamental right as well as the means for ensuring that other rights areobserved. The Constitution of Kenya under Article 48 provides for the right to access tojustice.6 The Article obligates the state to enhance mechanism for ensuring access to justice.This includes managing fees payable to an extent that it will not act as an impediment toadministration of justice. The Constitution also provides for obligation on the part of the stateof ensuring that measures are in place of adopting methods that can enable people seekjustice in alternative means. Article 159 provides that judiciary must promote resolution ofdisputes through alternative means which includes use of traditional dispute resolutionmechanism (TDRM).Though the Constitution requires certain impediments like fees be addressed by the state, thismight not been addressed to a satisfactory level, thereby leaving out a huge margin of thepopulation from accessing justice in the formal system. Beyond costs associated withlitigation, there exists a wide range of other factors that denies some people an opportunity toseek justice.1.3 Challenges in regard to administration of justiceColonisation in Africa brought with it among other factors foreign forms of disputeresolution. Mohamed claims that to a great extent, these mechanisms were prioritised by the5Cappelletti, M., & Garth, B. (1977). Access to Justice: The Newest Wave in the Worldwide Movement toMake Rights Effective. Buff Law review, 27, 11.6Constitution of Kenya, 2010; Article 4.5
colonial administration and disregarded the traditional justice systems that were in place. 7According to Price, most of the disputes resolution mechanisms that existed were muted bythe colonial administration.8 Noting that it was not possible to fully do away with TDRMs,the colonial administration provided for their application but subjected to certain limitations.9This was actualised by enactment of Natives Courts Regulations Ordinance that allowed useof customary law in native courts. However, this was co-opted later in the formal courts butuse of customary law limited through inclusion of repugnancy clause. Unfortunately therepugnancy to morality and natural justice was measured in the eyes of foreign concepts butnot in the African perspective. This was evidenced in the infamous case of R Versus Amkeyothat failed to recognise a marriage conducted under African customary practice on account of‘bride price’ being ‘wife purchase’.10 Pwiti and Ndoro claims that this pushed the Africanstates to primarily adopting the foreign justice systems as the main and formal ways ofresolving disputes.11 To a great extent, such practices continued at the formal level whereasthe traditional systems continued at the local level and in most cases in unstructured manner.The same arrangement continued further into independent states. This was seen inlegislations such as the Judicature Act of 1967. The Act allowed application of Africancustomary law in civil cases if found to be consistent with natural justice and morality.12However there were some modifications that allowed customary practices to be recognisedwhen brought to the attention of court. That was the case ain a number of succession caseshandled in various years.Though court process is the main means of resolving dispute, it has not been able to addressthe justice needs of the society.13 There have been a number of barriers in accessing justice incourts. In addition, Price notes that courts are faced with numerous cases that ought to beresolved at other avenues.14 There have been challenges of backlog of cases in courts; matterstaking long duration in courts as well delayed judgments. Such realities and practices hasMohamed, F. M. Y. (2018). African communities dispute settlement’s methods before advent ofcolonisation. Research Journal of English Language and Literature (RJELAL), 6 (3), 59-65.8Catherine Price, Alternative Dispute Resolution in Africa: Is ADR the Bridge Between Traditional and ModernDispute Resolution?, 18 Pepperdine Dispute Resolution Law Journal pg 395 (2018) Available 8/iss3/2.9Order-in Council Ordinance 1897 Article 52.10R versus Amkeyo is explained in chapter three.11Pwiti, G., and Ndoro, W., 1999, “The Legacy of Colonialism: Perceptions of Cultural Heritage in SouthernAfrica, with Special Reference to Zimbabwe,” African Archaeological Review 16, no. 3, pp. 143–153.12Judicature Act of 1967, section 3 Laws of Kenya.13Judiciary of Kenya, Alternative Justice System policy framework 2020.14Catherine Price, Alternative Dispute Resolution in Africa: Is ADR the Bridge Between Traditional andModern Dispute Resolution?, 18 Pepperdine Dispute Resolution Law Journal pg 395 (2018) Available 8/iss3/2.76
been delaying administration of justice and thereby tarnishing the image of courts as aninstitution of delivering justice. According to Muigua complex rules, cost of litigation andbacklog of cases are some of the barriers affecting courts as the main dispute resolutionmechanism.15According to UN Women, UNICEF and UNDP, due to complexity, tediousness and costsassociated with formal structures, majority of people at the community level have been leftwithout capacity to access justice in such mechanisms.16 Dammann and Hansmann, claimsthat increase in popularity on the other forms of resolving dispute other than litigation to agreat extent has been due to challenges in the formal structures.17Cappelletti argues that there are three main obstacles to access to justice. These obstacles areeconomic, procedural and organisational.18 He, therefore, proposes solution to them based oneach obstacle. For example in economic obstacles, Cappellatti argues that majority of peopleare not able to get information or adequate representation because of poverty. In his place,Muigua claims that majority of people are not aware about alternative means of resolvingdisputes.19 In such instances, Cappelletti proposes solutions such as creation of social rights,citizen action, action collective and creation of ombudsman.20On procedural factors, the courts have formal and complex rules that make some peopleunable to access justice. Further they are unable to afford legal representation in helping themnavigate through the complex rules.21 Beyond rules, there is requirement of documentationthat also require knowledge and expertise. This excludes those people who cannot draftdocuments or afford legal assistance from accessing justice in courts.On organisational barriers, a number of factors act as impediments to accessing justice in theformal structure. In some regions justice seekers have to walk for long distances in order for15Muigua, K. (2017). Institutionalising Traditional Dispute Resolution Mechanisms and other CommunityJustice Systems. Alternative Dispute Resolution, 1-80.16UN Women, UNICEF and UNDP, Informal Justice Systems: Charting a Course for Human RightsbasedEngagement (2013).17Dammann, J., & Hansmann, H. (2008). Globalizing commercial litigation. Cornell L. Rev., 94, 1.18Cappelletti, M. (1993). Alternative Dispute Resolution Processes Within the Framework of the World-WideAccess-To-Justice Movement. The Modern Law Review, 56(3), 282-285.19Muigua Access to Justice And Alternative Dispute Resolution Mechanism in Kenya pg 5-1120Cappelletti, M. (1993). Alternative Dispute Resolution Processes Within the Framework of the World-WideAccess-To-Justice Movement. The Modern Law Review, 56(3), 284-290.21UN Women, UNICEF and UNDP, Informal Justice Systems: Charting a Course for Human RightsbasedEngagement (2013).7
them to reach institutions of justice. Mwimali writes that most people in the frontier regionare very far from institutions of justice.22Economic, procedural and organisational barriers make accessing justice in courts a tollorder. Such barriers and challenges push some people either not to seek justice or resort toinformal processes.1.4 Alternatives to What?Alternative dispute resolution (ADR) is the mechanism of resolving disputes in any otherform other than through the court. The theory of ADR holds that resolution of disputes otherthan through litigation is more effective and expeditious.23 Black’s law dictionary definesalternative dispute resolution as a process of solving dispute other than litigation.24 Theprocess is said to be alternative presupposing existence of the main method of resolvingdispute. Some of the alternative justice processes include mediation, conciliation, negotiation,arbitration and traditional dispute resolution mechanisms. Reconciliation, mediation,arbitration and traditional dispute resolution mechanisms are specifically mentioned underArticle 159 of the Constitution.25It should be noted that disputes are part and parcel of the society. These disputes may beresolved at different levels depending on the form, nature and extent of dispute. In a wellstructured society, court as the main structure of resolving disputes should come as the lastresort. However due to lack of proper structures, Price opines that some of disputes that endup in courts could have amicably been resolved at other avenues.26Due to challenges associated with litigation, it becomes vital to adopt and recognise otheralternatives to resolving disputes.27 Alternative justice presupposes a situation that it willoffer a better platform to the main method. In this case, Price recommends that the22Mwimali, B.J., 2015. Human Rights Perspective of Informal Dispute Resolution Processes and the CriminalJustice System in Kenya. Law Society of Kenya Journal, 2 (2) 1-11.23Catherine Price, Alternative Dispute Resolution in Africa: Is ADR the Bridge Between Traditional andModern Dispute Resolution?, 18 Pepperdine Dispute Resolution Law Journal pg 395. (2018) Available 8/iss3/2.24Bryans Garner (2009). Black’s Law dictionary 9 th edition.25Constitution of Kenya, 2010 Article 159 (2).26Catherine Price, Alternative Dispute Resolution in Africa: Is ADR the Bridge Between Traditional andModern Dispute Resolution?, 18 Pepperdine Dispute Resolution Law Journal pg 395. (2018) Available 8/iss3/2.27Wojkowska, Ewa 2006: How Informal Justice Systems can contribute, Oslo: United Nations DevelopmentProgramme, Oslo Governance Centre pg 21.8
alternatives must address issues of cost, time taken in resolving a dispute, complexity of theprocess and accessible justice.28Ntuli claims that litigation being the main form of resolution of disputes is proving to be acomplex and sometimes expensive process.29 Such challenges prevent some quotas of thepopulation from not seeking justice in the court systems. Muigua and Francis find thatlitigation is faced with various disadvantages like delay, technical procedures and high coststhat give alternative dispute resolution a lee way in accessing justice. 30 They further hold thatrecognition of ADR and traditional dispute resolution mechanisms have contributed toenhanced access to justice especially to the poor.31Muigua argues that traditional dispute resolution mechanisms are flexible, affordable,expeditious and offer a friendly outcome.32 He further holds that their positive use will in turnlead to reduced backlog of cases in court.33 This is premised on the notion that ADRmechanism will be used in resolving most of the disputes that are filed in court that lead toclogging of cases in courts. Price claims that alternative dispute resolution and specificallytraditional justice system has been in use in Africa but in an informal way.34 She claims thatthe uniqueness of the African legal system cannot work without resorting to use of traditionalsystem that applies customary law in resolving disputes.35Muigua recommends sensitization be done to judges, magistrates, lawyers and the membersof the public on the appropriateness and effectiveness of ADR mechanism and its use will inturn lead to access to justice.36 In agreement with Muigua assertion, Price posits that access tojustice in Africa cannot be realised without strengthening alternative dispute resolution28Catherine Price, Alternative Dispute Resolution in Africa: Is ADR the Bridge Between Traditional andModern Dispute Resolution?, 18 Pepperdine Dispute Resolution Law Journal pgs 395 -396. (2018) Available 8/iss3/2.29Ntuli, N. (2018). Africa: Alternative Dispute Resolution in a Comparative Perspective. Conflict StudiesQuarterly, (22).30Muigua and Francis, Alternative Dispute Resolution, Access to justice and development in Kenya pg 1-4.31Muigua and Francis Alternative Dispute Resolution, Access to justice and development in Kenya pg 2.32Muigua K. (2015) Access to Justice: Promoting Court And Alternative Dispute Resolution Strategies pg 4.33Muigua K. (2015) Access to Justice: Promoting Court And Alternative Dispute Resolution Strategies pg 4.34Catherine Price, Alternative Dispute Resolution in Africa: Is ADR the Bridge Between Traditional andModern Dispute Resolution?, 18 Pepperdine Dispute Resolution Law Journal pgs 395 -396. (2018) Available 8/iss3/2.35Catherine Price, Alternative Dispute Resolution in Africa: Is ADR the Bridge Between Traditional andModern Dispute Resolution?, 18 Pepperdine Dispute Resolution Law Journal pgs 394-396. (2018) Available 8/iss3/2.36Muigua Access to Justice and Alternative Dispute Resolution Mechanism in Kenya pg 5.9
mechanism.37 Price advocates for adoption of ADR as the case is in Ghana of borrowingADR mechanism from the west but also integrate it with traditional mechanisms.38According to UN, informal justice system can come in and provide justice especially insituations where formal justice fails to achieve.39 Wojkowska argues that informal justicesystem provides culturally relevant remedies and is supported and seen as more legitimate atthe community level.40This paper proceeds to examine alternative justice in the context of traditional disputeresolution mechanisms. Findings are that the mechanism is (was) preferred for a number ofits benefits notably being its ability to grant restorative justice.1.5 Traditional Justice Systems as the AlternativeIn the traditional African society, disputes were resolved through mechanism establishedwithin the community and majorly based on customs and practices. Communities’ institutionsand leaders played an important role in resolving disputes. In most communities, thereexisted a council of elders that played an important role in resolution of disputes. Majorly,these council of elders comprised of men who had attained a certain age. According toJoireman, most disputes were therefore resolved through the men’s perspective.41Among the Ameru community there was (is) an institution of traditional leaders known asNjuri Ncheke.42 Kieyah and Khaoya write that members of the Nchuri Ncheke were elderlymen who met certain customary attainment.43 The institution was very instrumental intraditional society in resolving disputes existing in the society. The institution applied Amerucustomary law and practices in making their determination. Apart from resolving internal37Catherine Price, Alternative Dispute Resolution in Africa: Is ADR the Bridge Between Traditional andModern Dispute Resolution?, 18 Pepperdine Dispute Resolution Law Journal pgs 395 -396. (2018) Available 8/iss3/2.38Catherine Price, Alternative Dispute Resolution in Africa: Is ADR the Bridge Between Traditional andModern Dispute Resolution?, 18 Pepperdine. Dispute Resolution aw Journal 393 (2018) Available 8/iss3/2 pg 396.39Informal Justice System, Charting A Course For Human Rights Based Engagement.40Wojkowska, ewa 2006: How Informal Justice Systems can contribute, Oslo: United Nations DevelopmentProgramme, Oslo Governance Centre.41Joireman, S.F., "Inherited legal systems and effective rule of law: Africa and the colonial legacy," TheJournal of Modern African Studies Vol.39, No. 04, 2001, pp. 571-59642Mburugu, K. N., & Macharia, D. (2016). Resolving Conflicts using Indigenous Institutions: A Case Study ofNjuri-Ncheke of Ameru, Kenya.43Kieyah, J., & Khaoya, D. (2017). 7 Traditional institutions of the Meru, Pokot, and Mijikenda communities inKenya. Traditional Institutions in Contemporary African Governance, 1, 108.10
disputes, Njuri ncheke also played an important role in resolving external conflicts.44 NchuriNcheke has survived its role of resolving disputes over the years despite presence of formalcourts.45 The institution has helped in resolving disputes at the community level. In thecontemporary times, even courts have come to recognise the important role being played byNchuri Ncheke. In the case of Lubaru M’Imanyara versus Daniel Murungi46court agreed thata land matter be transferred to Njuri Ncheke for determination.Kenyatta writes that Kikuyu community had an organised form of governance before thecolonial invasion.47 He notes that resolution of disputes started at the lowest level of thesociety which was a family. Kenyatta notes that the head of every household was the fatherwho was entrusted in resolving disputes at the family level. If a dispute was not resolved atthe family level, United Nations reports that the matter was referred to the extended familyknown as ndundu ya muchii.48 It was only the most serious disputes that were taken to thecouncil of elders known as ndundu ya athuri. Kenyatta writes that Ndundu ya athuri wascomposed of elder men who had attained certain qualifications in the community. Theirproceedings were held in open places and members of the communities were free to attend.Kenyatta notes that parties to a dispute were notified and invited to the proceedings.49 Theywere free to call their witnesses and present their case to the elders. United Nations states thatthe decision given by the council of elders in Gikuyu was majorly to reconcile and restore therelationship of the parties.50 The elders could also order compensation to the aggrieved party.Enforcement of the decision was through societal pressures and it was unlikely to find a partynot complying with the decision of the council of elders.The Somali community had a traditional court known as maslah.51 These courts though stillfunctional to date, applied Somali customary law and practices. Sage writes that maslah also44Orina, H. K. (2018). The contributions of councils of elders to the resilience of African traditional religion. Acase of Njuri ncheke in Meru County, Kenya (Doctoral dissertation, Egerton University).45Orina, H. K. (2018). The contributions of councils of elders to the resilience of African traditional religion. Acase of Njuri ncheke in Meru County, Kenya (Doctoral dissertation, Egerton University).46 eKLR.47Kenyatta, J. (2015). Facing Mount Kenya: The Traditional Life of the Gikuyu. East African EducationalPublishers.48United Nations Human Rights Commission, ‘Human Rights and Traditional Justice Systems in Africa’,United Nations (2016) pp 21.49Kenyatta, J. (2015). Facing Mount Kenya: The Traditional Life of the Gikuyu. East African EducationalPublishers.50United Nations Human Rights Commission, ‘Human Rights and Traditional Justice Systems in Africa’,United Nations (2016) pp 17-28.51Mwimali J, ‘Human Rights Perspectives of Informal Dispute Resolution Processes and the Criminal JusticeSystem in Kenya’, 9.11
borrowed heavily from Islamic religious teachings.52 The courts hold their sittings in openplaces near markets or mosques. According to Sage, Somali customary courts providesrestorative and reconciliatory justice.53Despite adoption of English legal system many years ago, Kariuki notes that institution ofelders in resolving disputes have not been fully eroded at the community level.54 Traditionalpractices and mechanisms have continued in the modern society at the local level in a mannerthat is unregulated and not within the reach of the state operations. However, as Uwaizeargues, due to their ability to resolve disputes at the local level and in an affordable manner,they have become popular at the community level.55 Determination by traditional justicesystem is not about quality based on ‘entitlement’ but providing social harmony andorderliness.Article 159 (2) (c) of the Constitution provides that “alternative forms of dispute resolutionincluding reconciliation, mediation, arbitration and traditional dispute resolution mechanismsshall be promoted.” Further clause 3 of the Article provides that “Traditional disputeresolution mechanisms shall not be used in a way that contravenes the Bill of Rights; isrepugnant to justice and morality or results in outcomes that are repugnant to justice ormorality; or is inconsistent with this Constitution or any written law.” Article 11 (1) alsorecognises culture as the foundation and cumulative civilisation of Kenyan people. 56 Inaddition Article 19 (2) provides that human rights are recognised and protected in theConstitution with the purpose of preserving dignity of individuals and communities in orderto attain social justice and potentiality of all human beings. As noted by Price, this is thespirit that drove the African way of life as evidenced in their humane practices.57 In additionto the provisions discussed above, Article 60 provides a number of principles in regard toland management and use inclusive of “encouragement of communities to settle land disputesthrough recognised local community initiatives consistent with this Constitution.” Further,the National Land Commission functions under Article 67 of the Constitution includeLe Sage, “Stateless justice in Somalia”.Le Sage, “Stateless justice in Somalia”.54Kariuki, F. (2015). Conflict resolution by elders in Africa: Successes, challenges andopportunities. Alternative Dispute Resolution, 3(2), 30-53.55Uwazie, E. (Ed.). (2014). Alternative dispute resolution and peace-building in Africa. Cambridge ScholarsPublishing pg 2-5.56Constitution of Kenya, 2010.57Catherine Price, Alternative Dispute Resolution in Africa: Is ADR the Bridge Between Traditional andModern Dispute Resolution?, 18 Pepperdine Dispute Resolution Law Journal pgs 395 -396. (2018) Available 8/iss3/2.525312
encouragement of the application of traditional dispute resolution mechanisms in resolvingland conflicts.58 Article 50 (9) of the Constitution and Victim Protection Act59 provides forthe rights, protection and welfare of victims of offences. The judiciary of Kenya has made astride towards promotion of TDRMs by establishing the alternative justice policyframework.60 The policy reports that majority of people do not seek justice in courts forvarious reasons. The policy framework recommends recognition of autonomous alternativejustice system institutions or court annexed alternative justice system institutions in dealingwith cases based on customary traditions and practices. Though the policy is still at theinfancy stage, a lot still remains to be done towards adopting and use of traditional justicesystems within the legal framework. The law in the Constitution has not been brought out tothe practice to benefit the Kenyan society as anticipated. The robust bill of rights cannot beenjoyed without proper mechanism of accessing justice.If traditional justices systems operate in an unstructured and unregulated environment, itbecomes difficult to know and understand the extent to which they conform to therequirement of the Constitution. TDRMs can be an enabler or impediment to access to justicedepending on how they operates, functions and deals with issue
Research Journal of English Language and Literature . 59-65. 8 Catherine Price, Alternative Dispute Resolution in Africa: Is ADR the Bridge Between Traditional and Modern Dispute Resolution?, 18 Pepperdine Dispute Resolution Law Journal pg 395 (2018) Available . 18 Pepperdine Dispute Resolution L
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