defender working for the Zimbabwe Human Rights NGO Forum. A combination of State forces was allegedly involved in the arrest and subsequent torture, including CIO and military personnel as well as uniformed and plain-clothed police. The torture was used to force confessions from them. When they were brought to court the evidence of torture was obvious and the charges were dropped. Section 37 of the Public Order and Security Act has far-reaching provisions that allow the army to be brought in to assist the police in suppressing a civil commotion or disturbance. Essentially the Police Commissioner can request such assistance in a police district. If his Minister is satisfied that such assistance is necessary, the Minister can request the Defence Minister to authorise the army to assist the police. Army personnel so assigned are under the command of the police regulating authority. When performing this function, a member of the army:     has the same powers, functions and authority as a policeman; is subject to the same responsibilities, discipline and penalties as a policeman; is liable for his acts or omissions to the same extent that a policeman would have been liable in the same circumstances; has the benefit of any indemnity to which a policeman would be entitled to in the same circumstances. In the past the army has quite often assisted the police violently to suppress public protest or to exact reprisals for public protests. When the army is brought into these situations, levels of brutality tend to increase. Army personnel are not trained to use minimum force and may well act without reasonable constraint. The army is supposed to be under the command of the police regulating authority. However, in practice the army commanders will often call the tune. In any event police commanders themselves may order or encourage the use of unlawful force. There have been a number of court cases in which the Ministry of Defence has been successfully sued for damages for the use of excessive force used by the army to suppress protests or deal with persons engaging in strike action. In the case of Gweshe v Minister of Defence48 the plaintiff successfully claimed damages from the Minister of Defence for injuries sustained by her in 2003 as a result of being severely assaulted at her home in Harare by members of the Army after deployment of units of the Army in the highdensity suburbs of Harare in support of the police following upon protest action. 48 Case HH-28-2006 Who guards the guards? Violations by the Zimbabwe Republic Police, 2000 to 2006