The response to Dabdoub's appeal against the Chief Justice's order for a by-election is centred around three main submissions. The concept of "votes thrown away" in relation to Parliamentary Elections being a doctrine reated under the English system of law is incompatible with the nature and structure of the Constitution of Jamaica. Furthermore, the concept of votes thrown away is unconstitutional. The express language of S.40(2)(a) of the Constitution of Jamaica requires a finding that the individual has conducted himself in doing some action which acknowledges allegiance, obedience or adherence to a Foreign Power or State. The facts in the Notice of Disqualification were unclear, indefinite and uncertain . The detailed submissions are set out below: Publish at Scribd or explore others: