of Kenyans would have rejected the constitution in the referendum to adopt it. Nevertheless, few argue that Kenya's statutes discriminating against LGBTI persons are unconstitutional and void because of the constitution's broad protection of civil and human rights. Peter Anaminyi, the national director of Feba Radio Kenya, predicted in June 2011 that within 18 months there would be a challenge to the constitutionality of the Kenya Penal Code. Article 2 Article 2 of the Constitution of Kenya provides, in paragraph (5) that "the general rules of international law shall form part of the law of Kenya" and, in paragraph (6), that "[a]ny treaty or convention ratified by Kenya shall form part of the law of Kenya under this Constitution". In paragraph (4), the constitution states, "[a]ny law, including customary law, that is inconsistent with [the] Constitution is void to the extent of the inconsistency, and any act or omission in contravention of [the] Constitution is invalid." A subsequent section of this article lists Kenya's obligations under international law and treaties concerning LGBTI rights. To the extent that any Kenyan law violates Kenya's voluntary or involuntary obligations under international law, the law is arguably void under Article 2. Article 10 Article 10(2)(b) of the Constitution of Kenya provides that, "The national values and principles of governance include ... human dignity, equity, social justice, inclusiveness, equality, human rights, non-discrimination and protection of the marginalised...." Concerning this provision, "Right there, there is a firm basis [for] one to argue against the violation of their [LGBTI persons'] dignity ... on the basis of their gender or sexual orientation. There is firm ground to contest for inclusion, non-discrimination and equality too". Article 19 Article 19 of the Constitution of Kenya provides that, (1) The Bill of Rights [Articles 19-59] is an integral part of Kenya’s democratic state and is the framework for social, economic and cultural policies. (2) The purpose of recognizing and protecting human rights and fundamental freedoms is to preserve the dignity of individuals and communities and to promote social justice and the realization of the potential of all human beings. Article 20 Article 20(3)(b) of the Constitution of Kenya requires courts, when applying a provision of the Bill of Rights, to "adopt the legal interpretation that most favours the enforcement of a right or fundamental freedom". Concerning this article, Makau Mutua, the chair of the Kenya Human Rights Commission and the dean