In Monica Munira Kibuchi v. Mount Kenya University, the Court ruled that probationary employees are still entitled to a fair hearing.

Section 42(1) of the Employment Act which tried to exclude them from the protections prescribed under Section 41 was declared unconstitutional for violating Articles 41 and 47 of the Constitution.

Takeaway:
Being on probation does NOT extinguish the right to procedural fairness before termination.