In May 1920, white European settler Langley Hawkins discovered money and documents were missing from his house in Kiambu County in the British East Africa Protectorate.

The case was one of a number of similar outcomes that raised concern in the British Colonial Office over the widespread practice of flogging by European settlers in Kenya.

Numerous attempts at reform eventually saw the replacement of the colony's Indian Penal Code and other measures to restrict the discretion allowed to juries and judges in murder and battery cases.

Langley Hawkins was a settler, of European descent, in Kiambu County of the East Africa Protectorate (present-day Kenya).

[1]: 485 The case was widely reported in the local press and a subscription was raised among European settlers to meet the cost of a trial.

Later reforms under Governor Sir Joseph Byrne, which made him unpopular among the European population, reduced the discretion available to judges on sentencing.

European public opinion in the colony remained strongly in favour of harsh treatment to black Kenyans for decades.