Judgment No. CCZ 05/18 5 Const. Application No. 32/17 second respondent to prepare an election that is based on fair regulations and practices. Section 235 of the Constitution provides as follows: 235 Independence of Commissions (1) The independent Commissions— (a) are independent and are not subject to the direction or control of anyone; (b) must act in accordance with this Constitution; and (c) must exercise their functions without fear, favour or prejudice; although they are accountable to Parliament for the efficient performance of their functions. (2) … (3) No person may interfere with the functioning of the independent Commissions. The applicant’s contention is that the requirement for the first respondent to approve the regulations places the second respondent under his “direction and control” and allows him to interfere with the functions of ZEC. The pertinent issue to be determined in this judgment is the interpretation to be accorded the phrase ‘direction and control’ in relation to the requirement for the first respondent to ‘approve’ the regulations. In other words, is the ‘approval’ that is required of the Minister in terms of s 192 (6) of the Electoral Act tantamount to the ZEC being subject to his direction and control? It is trite that in construing the provisions of the Constitution, the primary rules of statutory interpretation apply. This was highlighted by this Court in Chihava and Others v Provincial Magistrate and Another 2015 (2) ZLR 31 (CC) where it stated at page 35: “In this respect, it is pertinent to note that a constitution is itself a statute of Parliament. Therefore, any rules of interpretation that are regarded as having particular relevance in relation to constitutional interpretation, can only be additional to the general rules governing the interpretation of statutes …”