A. Legal Standards
1. Prohibition
{¶ 12} To obtain a writ of prohibition, the protestors must show that (1) the board exercised quasi-judicial power, (2) the exercise of that power was unlawful, and (3) the protestors have no adequate remedy in the ordinary course of the law. State ex rel. McCord v. Delaware Cty. Bd. of Elections , 106 Ohio St.3d 346, 2005-Ohio-4758, 835 N.E.2d 336, ¶ 27. The board exercised quasi-judicial power when it denied the protest after a hearing that included sworn testimony. See id. at ¶ 28. And due to the proximity of the election, the protestors lack an adequate remedy at law. Id. at ¶ 29. The question is, then, whether the protestors have shown that the board engaged in fraud or corruption; abused its discretion, i.e., acted in an unreasonable, arbitrary, or unconscionable fashion; or clearly disregarded applicable legal provisions. Id. at ¶ 30.
2. Liberal Construction, Strict Compliance, Substantial Compliance
{¶ 13} "[R]eferendum provisions should be liberally construed to permit the exercise of the power." S.I. Dev. & Constr., L.L.C. v. Medina Cty. Bd. of Elections , 100 Ohio St.3d 272, 2003-Ohio-5791, 798 N.E.2d 587, ¶ 22. But once their requirements are determined, "the settled rule is that election laws are mandatory and require strict compliance and that substantial compliance is acceptable only when an election provision expressly states that it is." State ex rel. Ditmars v. McSweeney , 94 Ohio St.3d 472, 476, 764 N.E.2d 971 (2002) (plurality opinion).
*2293. Referendum Statutes
{¶ 14} The applicable legal provisions are R.C. 519.12(H) and 3501.38(E). R.C. 519.12(H) provides that a township zoning amendment shall become effective 30 days after a board of township trustees approves it, unless within that time period the trustees receive a petition asking them to submit the amendment to the voters at the next election and the petition is signed by a number of electors residing in the unincorporated areas of the township that is not less than 8 percent of the total votes cast for governor in the unincorporated areas of the township in the most recent gubernatorial election.
{¶ 15} R.C. 519.12(H) contains only a few strict requirements for township-zoning-referendum petitions. First, each part-petition "shall contain the number and the full and correct title, if any, of the zoning amendment resolution, motion, or application, furnishing the name by which the amendment is known and a brief *19summary of its contents." R.C. 519.12(H). Second, "each petition shall be governed by the rules specified in [ R.C. 3501.38 ]." R.C. 519.12(H).
{¶ 16} R.C. 3501.38(E)(1), the subsection relevant here, states:
On each petition paper, the circulator shall indicate the number of signatures contained on it , and shall sign a statement made under penalty of election falsification that the circulator witnessed the affixing of every signature, that all signers were to the best of the circulator's knowledge and belief qualified to sign, and that every signature is to the best of the circulator's knowledge and belief the signature of the person whose signature it purports to be or of an attorney in fact acting pursuant to [ R.C. 3501.382 ].
(Emphasis added.) R.C. 519.12(H) provides that "[t]he form of a petition calling for a zoning referendum and the statement of the circulator shall be substantially as follows." (Emphasis added.) It then sets forth a sample form that incorporates a blank for the number of signatures witnessed into the circulator statement that is to be signed under penalty of election falsification. Id.
{¶ 17} R.C. 519.12(H)'s third strict requirement is that the petition "shall be filed with the board of township trustees and shall be accompanied by an appropriate map of the area affected by the zoning proposal."
B. Indication of the Number of Signatures
{¶ 18} The protestors argue that the board abused its discretion and acted in clear disregard of the law by denying their protest against part-petition No. 2, because its circulator statements were modified by Perry after the circulator, Berk, signed them. We agree.
{¶ 19} R.C. 3501.38(E)(1) states: "[T ]he circulator shall indicate the number of signatures contained on" each petition paper. (Emphasis added.) "The purpose of this requirement is to protect against signatures being added after the circulator's statement is made." Rust v. Lucas Cty. Bd. of Elections , 108 Ohio St.3d 139, 2005-Ohio-5795, 841 N.E.2d 766, ¶ 11 (denying writ of mandamus when board of elections had rejected part-petitions because they understated the number of signatures); see also State ex rel. Loss v. Lucas Cty. Bd. of Elections , 29 Ohio St.2d 233, 233-234, 281 N.E.2d 186 (1972) (denying writ of mandamus when board of elections had rejected part-petition because space for indicating the number of signatures witnessed was left blank).
*230R.C. 3501.38(E)(1) does not permit substantial compliance; the petitioners were required to strictly comply with it.
*20State ex rel. Commt. for Referendum of Lorain Ordinance No. 77-01 v. Lorain Cty. Bd. of Elections , 96 Ohio St.3d 308, 2002-Ohio-4194, 774 N.E.2d 239, ¶ 49.
{¶ 20} In addition, form 6-O incorporates the blank for the number of signatures witnessed into the circulator statement (as in R.C. 519.12(H)'s sample form) and instructs that the statement "[m]ust be completed and signed by the circulator ." (Emphasis added.) This court has looked to the design of the secretary of state's forms to suggest the secretary's interpretation of statutes, to which this court typically gives "great deference." State ex rel. Crowl v. Delaware Cty. Bd. of Elections , 144 Ohio St.3d 346, 2015-Ohio-4097, 43 N.E.3d 406, ¶ 10. And the secretary has admonished that "[t]he entire part-petition is invalid if the circulator's statement is not completed as required by law." Secretary of State Directive 2017-15, Section 1.02(G), Ohio Election Official Manual at 11-6.
{¶ 21} It is undisputed that here, the circulator, Herman Berk, was not the person who wrote in the number of signatures witnessed on part-petition No. 2. The part-petition therefore did not strictly comply with R.C. 3501.38(E)(1).
{¶ 22} The board makes a case for essentially deeming Perry's writing to be the act of Berk, because Perry wrote the number of signatures Berk had witnessed in Berk's presence, with Berk's knowledge, in response to Berk's request for assistance, and before the part-petition left Berk's possession and because R.C. 3501.38(E)(1) requires the circulator to "indicate" the number of signatures, not to "write" the number "in [his] own hand."
{¶ 23} However, even if R.C. 3501.38(E)(1), liberally construed, countenanced "indicat[ion]" of the number of signatures by Berk through Perry, the secretary's interpretation of the requirement on form 6-O is owed deference. And the board's argument that the secretary's interpretation should be read in the disjunctive, i.e., as setting forth one requirement that the circulator statement be "completed [by anyone]" and another that it be "signed by the circulator," strains credulity. The instruction clearly requires the circulator to both complete and sign the statement. Here, the circulator complied with only one of those requirements.1
{¶ 24} We conclude that the board abused its discretion by denying the protest as to part-petition No. 2. The rejection of part-petition No. 2 brings the number of valid signatures to 99. Because the petitioners did not submit at least 116 valid signatures, the referendum cannot proceed to the ballot.
*21IV. CONCLUSION
{¶ 25} For the foregoing reason, we grant a writ of prohibition and order the board to remove the referendum from the ballot. Because we grant the writ for this reason, we do not reach the protestors' remaining arguments.
Writ granted.
O'Connor, C.J., and O'Donnell and DeGenaro, JJ., concur.
DeWine, J., concurs in judgment only, with an opinion joined by Fischer, J.
Kennedy, J., dissents, with an opinion joined by French, J.
DeWine, J., concurring in judgment only.
*231{¶ 26} I agree with the lead opinion that part-petition No. 2 was not in compliance with the statutory requirement and, therefore, the referendum was not properly certified to the ballot. I write separately because rather than simply relying upon the plain language of the statute, the lead opinion largely premises its result on the "great deference" it gives to the secretary of state's interpretation of the statute, lead opinion at ¶ 20. In an appropriate case, we ought to take a hard look at our practice of deferring to statutory interpretations made by administrative agencies and nonjudicial officials. But this case can be decided without reaching the subject of deference.
{¶ 27} There are two problems with the lead opinion's approach. First, deference to the secretary's interpretation is unnecessary; the plain language of the statute is all we need to decide the case. Second, that deference is unwarranted; it is our job, not the secretary's, to issue final interpretations of the law.
{¶ 28} This court has said that " 'when faced with a problem of statutory construction, [it will] show[ ] great deference to the interpretation given the statute by the officers or agency charged with its administration.' " State ex rel. Brown v. Dayton Malleable, Inc. , 1 Ohio St.3d 151, 155, 438 N.E.2d 120 (1982), quoting Udall v. Tallman , 380 U.S. 1, 16, 85 S.Ct. 792, 13 L.Ed.2d 616 (1965). In accord with this principle, we have deferred to the secretary of state's reasonable interpretation of the state's election laws. See, e.g. , State ex rel. Lucas Cty. Republican Party Executive Commt. v. Brunner , 125 Ohio St.3d 427, 2010-Ohio-1873, 928 N.E.2d 1072, ¶ 23.
{¶ 29} But here, the statute is clear: it requires the circulator to "indicate" the number of signatures. R.C. 3501.38(E)(1). It is uncontroverted that the circulator did not indicate the number of signatures; someone else did. There is no need to *22defer to the secretary's interpretation; the plain language of the statute is all we need to decide the case.
{¶ 30} Nevertheless, the lead opinion in large part premises its decision on the secretary's interpretation of the statute. Judicial deference to an agency's interpretation of a statute is at odds with the separation-of-powers principle that is central to our state and federal Constitutions. It has long been understood that part of the judicial power is to "say what the law is." Marbury v. Madison , 5 U.S. (1 Cranch) 137, 177, 2 L.Ed. 60 (1803). The Ohio Constitution, like the federal Constitution, allocates power among three distinct branches of government. "The judicial power of the state is vested in a supreme court, courts of appeals, courts of common pleas and divisions thereof, and such other courts inferior to the supreme court as may from time to time be established by law." Ohio Constitution, Article IV, Section 1.
{¶ 31} Deference to an administrative agency's interpretation of the law, however, "wrests from Courts the ultimate interpretative authority to 'say what the law is,' * * * and hands it over to the Executive." Michigan v. Environmental Protection Agency , --- U.S. ----, 135 S.Ct. 2699, 2712, 192 L.Ed.2d. 674 (2015) (Thomas, J., concurring), quoting Marbury at 177. In following this rule, we abandon our role as an independent check on the executive branch. See *232Perez v. Mtge. Bankers Assn. , --- U.S. ----, 135 S.Ct. 1199, 1219, 191 L.Ed.2d 186 (2015) (Thomas, J., concurring). In addition, judicial deference to administrative agencies on matters of legislative interpretation aggrandizes the power of the administrative state at the expense of the judiciary and officials directly accountable to the people. See Arlington, Texas v. Fed. Communications Comm. , 569 U.S. 290, 312-317, 133 S.Ct. 1863, 185 L.Ed.2d 941 (2013) (Roberts, C.J., dissenting).
{¶ 32} Although not as well developed, our practice of deferring to an administrative agency's statutory interpretations is similar to the doctrine applied in federal courts, see Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc. , 467 U.S. 837, 843, 104 S.Ct. 2778, 81 L.Ed.2d. 694 (1984). (In some respects, our practice could be seen as more expansive than the doctrine that is applied in federal courts because under Chevron , a statutory provision must be ambiguous before a court will defer to an agency's interpretation, id. As is evidenced by today's lead opinion, we have not consistently imposed that requirement.)
{¶ 33} The federal Chevron deference doctrine has come under severe and repeated criticism. See, e.g. , Christopher J. Walker, Attacking Auer and Chevron Deference: A Literature Review , 16 Geo.J.L. & Pub. Policy 103 (2018); Philip Hamburger, Chevron Bias , 84 Geo.Wash.L.Rev. 1187 (2016). And in recent years, the United States Supreme Court has pulled back on the reach of Chevron deference. In King v. Burwell , --- U.S. ----, 135 S.Ct. 2480, 2488-2489, 192 L.Ed.2d 483 (2015), the court refused to apply the Chevron deference doctrine to *23a matter of "economic and political significance." And in Michigan v. Environmental Protection Agency , the court rejected the agency's interpretation as "stray[ing] far beyond" Chevron 's reasonable-interpretation standard. --- U.S. ----, 135 S.Ct. at 2706-2707. State courts have also recently taken a fresh look at their administrative-deference doctrines, with at least two states retreating from doctrines that afforded deference to agency interpretations of law. Tetra Tech EC, Inc. v. Wisconsin Dept. of Revenue , 382 Wis.2d 496, 2018 WI 75, 914 N.W.2d 21 ; King v. Mississippi Military Dept. , 245 So.3d 404 (Miss.2018).
{¶ 34} I share the above concerns that have been expressed about judicial deference to agency interpretations of laws. But this proceeding-an expedited elections matter with limited briefing and a quick turnaround-is not the appropriate one in which to give our administrative-deference practice the review it deserves. I look forward to a case that squarely puts the issue before us. As for this case, there is no need to get to deference; we ought to simply apply the statute as written.
Fischer, J., concurs in the foregoing opinion.