Article 180 just prescribes the minimum qualifications, assuming that Parliament can impose other reasonable requirements. The argument by the court that no specific educational qualifications were made for governors and that the educational qualifications for MCAs and governors should be similar is unduly textual and ignores the questions of their respective roles and responsibilities.
The judgement raises several issues about suitability for office relative to functions. The question of educational qualifications for elective office has been part of Kenya's debate on suitability for office since the promulgation of the 2010 Constitution. In 2013 and 2017 elections, MPs enacted requirements for educational qualifications for MCAs and MPs but waived the requirement for the ensuing elections; no prizes for guessing why this was done.