Moreover, the Food and Agricultural Organization of the United Nations (FAO) warns that, while land titling programmes have become popular with many international agencies and beneficiaries, attempts to formalize land titling and registration can have unintended consequences forwomen.includingthe loss of secondary land rights under customary law (FAO, 2013). For example, when land registration programmes were first introduced in Kenya, the male-dominated adjudication committees typically registered land to the male head of household, but failed to record women’s secondary rights to the land. This had the unintended effect of extinguishing those rights altogether (FAO, n.d.). The Kenyan Constitution, as amended in 1997, prohibited discrimination based on gender.