threatening, abusive or insulting words or behaves in a threatening, abusive or insulting manner with intent to provoke a breach of the peace or whereby a breach of the peace may be occasioned. Section 7 (c) makes it an offence punishable by a fine or imprisonment of up to one year if a person employs any means whatsoever which are likely materially to interfere with the ordinary comfort, convenience, peace or quiet of the public or which are likely adversely to affect the safety of the public or does any act which is likely to lead to a breach of the peace or to create a nuisance or obstruction. The Zimbabwe Electoral Commission Act The Zimbabwe Electoral Commission (ZEC) Act creates the Zimbabwe Electoral Commission as an ostensibly independent supervisory electoral body. The Act gives the president and the ruling party excessive power to appoint commissioners and creates too many opportunities and requirements for ministerial power to intervene in the Zimbabwe Electoral Commission. The ZEC Act also makes voter education an effective monopoly of the partisan ZEC. Nongovernmental organizations may only provide voter education if they are registered under the Non-Governmental Organizations Act (still to be assented to by the president) and if the ZEC approves their participation and their voter education materials. Only the ZEC may receive foreign funding for voter education. This provision effectively prevents most NGOs, which have depended on foreign funding, from providing voter education. The introduction of the ZEC has created confusion about whether it or the Electoral Supervisory Commission (ESC) has supreme authority. The ESC is also supposed to be an independent body that supervises elections. The ESC enjoys a constitutional mandate, which is consistent with the trend for electoral commissions in SADC countries, whereas the ZEC is governed by an act of parliament. Whether the ESC or the ZEC is deemed supreme, the role of the president in the appointment of ESC and ZEC commissioners guarantees that both bodies are partisan and not independent. The ZEC Act and the Electoral Act prescribe different functions for the ZEC and the ESC, thereby fragmenting rather than concentrating electoral authority. For example, the ESC is involved in observer accreditation and election monitoring in which the ZEC has no role. The ZEC only became operational in February 2005. By this time, the ESC had supervised the registration of voters and the inspection of the voters’ roll. The 33