most of key perpetrators from the colonial era are too old, dead or are no longer residing in the country. Much more importantly, focus on individual responsibility exposes the limitations of international law, which attends to physical rights violations and not the far-reaching effects of colonialism in post-colonial societies. There is a common proclivity in Western legal renditions to offer a universalistic positivist approach to international legal issues. Yet, in addition to the failure to account for violations of bodily integrity rights, there are a number of indirect ways in which colonialism fostered the culture of impunity in former colonies. Opportunities – Previous Attempts at Truth Recovery There have been state led attempts at truth recovery, initiatives by domestic and international organisations and unofficial recording of history in vernacular novels. State–led truth seeking initiatives As discussed above, at independence the Mugabe regime adopted a policy of reconciliation and subsequently granted amnesties to human rights abusers in all key historic periods. Heroes and Independence Day celebrations commemorate the colonial legacy. Much more specifically, in response to allegations of post–independence human rights abuses and demands for the truth, the government established Commissions of Inquiries. For example, when faced with allegations of human rights atrocities in military camps in 1981, the government reacted by setting up a judicial commission of inquiry. Justice Enoch Dumbutshena chaired this body, which investigated the events but was precluded from publicising its findings. In 1983, another commission, chaired by Simplicius Chihambakwe was established to look into reports of killings of civilians by the army in Matabeleland. Again the report was not published. Thus there is no official truth; fact-finding has been largely confined to efforts of non-governmental organisations and academics. Civil society led initiatives Nevertheless, in addition to state led initiatives, the country's opposition parties and civic society have made parallel efforts. They have documented allegations of political violence, pursued civil claims against the state and examined possible justice options. Civil society has also attempted domestic and international litigation on behalf of post-independence human rights victims. 30 The Second International Conference on Transitional Justice in Zimbabwe