15.1. Firstly, in terms of s40C(1)(c) of the Electoral Act, political parties can conduct voter education. 15.2. Secondly, the request that was made by ZANU PF to the Electoral Commission was that they be provided with sample ballots for each electoral race contested in the 2018 general election i.e. a sample ballot relating to each constituency or ward under contestation in the poll. The response by Dr. Qhubani Moyo was that the Electoral Commission would only give each political party three sample ballots, one for presidential elections, another for House of assembly elections and one for local authority elections. This is what was made available to all political parties including the applicant’s own party. I attach hereto an affidavit by Dr. Qhubani Moyo relating to this issue marked Annexure ‘H’. 15.3. Thirdly, there is no basis for the allegation that the provision of sample ballot papers, which was done for every political party contesting the election, created fertile ground for rigging through ballot swapping and stuffing. I attach hereto, marked Annexure ‘I’, a sample ballot for the presidential, house of assembly and local authority elections. These sample ballots are clearly endorsed “SAMPLE”. How such a ballot could be swapped and pass for the actual ballots used in the election is again not explained by the applicant. 15.4. Further, and in any event, if the applicant holds a well-grounded fear that there was ballot swapping and stuffing using sample ballots in the election, he

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