In 2016, a petition was filed in court (Malindi Law Society versus the Attorney General of Kenya & Another (Petition No. 19 of 2016)) challenging the provisions of section 12A of the Land Act which made it mandatory for foreigners seeking to own first and second-row beach plots in Kenya to obtain consent from the Cabinet Secretary for Lands and Physical Planning. The court issued a conservatory order that barred the implementation of section 12A in 2016 pending the full hearing and determination of the Petition.