evidence alleged to be contained therein is, therefore, evidence that is no longer capable of finding its way into the record. 6. Ad Para 4.5 This is denied. Both the 23rd respondent and I as its chairperson are and have always been independent, transparent and accurate in the conduct of our functions. This is clearly confirmed by various election observer missions, (reports attached and related to in detail below), that have found the 2018 Zimbabwe general elections to have been conducted in a manner that was substantively and procedurally free, fair and credible. 7. Ad Para 4.5.1-4.5.3 This is denied. 7.1. Firstly, the footage and newspapers that the applicant refers to were never served upon me or the 23rd and 25th respondents. It is difficult to effectively engage with the issue raised by the applicant in this respect in the absence of the evidence upon which he bases his allegations against the 23rd respondent and the conduct of the state-owned media. 7.2. Secondly, because the evidence sought to be relied upon is absent from the applicant’s papers whish were served on us, it cannot readily be ascertainable as to whether what the applicant complains of against the state-owned media is editorial in nature or not. I say so considering the provisions of s 61(4)(a) of the

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