25.1. The applicant has not established, through evidence, the averments in his
paragraph 4.5.37 and having failed to do so the follow up in paragraphs 4.5.38
and 4.5.39 do not arise.
25.2. As already averred, any complaints received by the Electoral Commission
were referred to the ZRP and the Human Rights Commission for appropriate
action.
25.3. The applicant has not placed before the court any complaint lodged with the
Electoral Commission alleging a malpractice in terms of s136(1)(c) of the
Electoral Act let alone the subsequent evidence, had such complaint been placed
before the court, that the Electoral Commission did not act upon it.
26. Ad Para 4.4.40- 4.4.43
This is denied. I refer to the various observer reports that I have attached hereto
which give the electoral process administered by the Electoral Commission a passing
grade in terms of freeness, fairness and credibility.
27. Ad Para 4.6
This is denied.
27.1. The A series, attached to the founding papers, consists of five V11 forms.
There was a total of 10 985 polling stations in operation during the 2018 general
election. There are also ten provinces in Zimbabwe thus at least five provinces
are not represented on the V11s forming the applicant’s A series. Five V11s out
Select target paragraph3
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