“I have been a sex worker for 16 years. Our working conditions have improved over the years. They used to beat us in Nairobi, so l came to Mombasa. In Nairobi, l paid fines, was arrested and arraigned in court several times and jailed five times.” Whilst the Kenyan Penal Code does not criminalize sex work, the Mombasa Municipal Council by-laws criminalizes loitering, procuring or attempting to procure for the purpose of prostitution. The by-law is often criticized for its vague definition and gender bias.