Torture itself was the largest category of human rights violations reported to the members of the Forum in the reporting period. Cases of torture that occurred during the Parliamentary Election are specifically excused by the Presidential Clemency Order of October 2000. This order did not excuse murder, rape, or crimes involving corruption, but did specifically exclude from prosecution, assault, assault with intent to commit grievous bodily harm, and crimes against property. Given the number of reports indicating State complicity in torture during the period covered by the amnesty, it can only be concluded that the State has sought to avoid exposure through the amnesty. Of course the Clemency Order cannot avoid civil liability for the acts committed, but it is clear that very few of the victims will have the resources to follow such a course of action. Furthermore, given the numbers involved – one estimate put the probable number of torture victims in 2000 alone at 200,000 – the sheer scale of the problem precludes civil litigation as a sensible course of action. Secondly, in a small number of cases there has been an attempt to demonstrate legally that torture has occurred and that the State has been involved, or, more 14 properly, that State officials have been involved. The most notorious of these cases involves Chief Inspector Henry Dowa, whose involvement in torture has been documented in considerable detail in an attempt to obtain international 15 justice. Dowa was seconded to the Civilian Police Unit of the United Nations Interim Administration in Kosovo (UNMIK), and an attempt was made by REDRESS, representing several of Dowa’s alleged victims, to persuade UNMIK to try Dowa for the alleged acts of torture. In the final event, the United Nations declined to accept any responsibility for trying Dowa, and eventually returned Dowa to Zimbabwe, with a request that the Zimbabwe authorities undertake “a prompt and full investigation into the allegations against him, with a view to his possible prosecution”. It is noteworthy that no such investigation has taken place, and indeed that Chief Inspector Dowa has been reported several times since his return as having been party to further human rights violations. January 2002; Physicians for Human Rights (2002), Zimbabwe: Post Presidential Election – March to May 2002. “We’ll make them run”. Physicians for Human Rights, Denmark, 21 May 2002. 14 See here the recent judgement of Justice Mungwira in the Cain Nkala murder trial, where the Judge concluded unequivocally that the accused warned and cautioned statements had been extracted under conditions of duress or torture. 15 See REDRESS. The Case of Henry Dowa: The United Nations and Zimbabwe under the spotlight, January 2004. 23