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

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