public health.”15 Nevertheless, Zimbabwe has several laws in place that continue to limit Zimbabweans’ rights to freedom of expression and information in violation of its international obligations. For example, the Broadcasting Services Act, enacted in 2001, allows for private broadcasting and provides for the issuance of licenses, but the application procedures are so complex and stringent that at present no licenses have been issued other than to the governmentcontrolled Zimbabwe Broadcasting Corporation (ZBC). The Broadcasting Services Act provides that the Broadcasting Authority of Zimbabwe shall determine the need for additional broadcasting services and invite applications for licenses; unsolicited applications are not entertained.16 Local media analysts have noted that the act’s prohibitively high application cost discourages new investors.17 As mentioned above, the Access to Information and Protection of Privacy Act (AIPPA), enacted in 2002, prohibits the full-time employment of unaccredited journalists in Zimbabwe by news agencies and the mass media. In addition, the Public Order and Security Act (POSA), also enacted in 2002, criminalizes “publishing or communicating statements prejudicial to the State” and prohibits “undermining authority of, or insulting the President.”18 The phrase has been interpreted broadly to prosecute critics of the president, his government, and his policies. The Criminal Law (Codification and Reform) Act of 2004 covers several offenses already included in the AIPPA and POSA, such as laws relating to the publication of falsehoods that are viewed as prejudicial to the state and insulting to the president of Zimbabwe. The prescribed penalty for violation of sections of the law related to freedom of expression is 20 years in prison.19 15 Constitution of Zimbabwe, published as a schedule to the Zimbabwe Constitution Order 1979, (S.I. 1979/1600 of the United Kingdom), art. 20. 16 The Broadcasting Services Act, 2001, art. 10. 17 Human Rights Watch interviews with media analysts M.C., D.K., and D.C., Harare, February 7, 2010. 18 Public Order and Security Act, 2002, chap. 11:17, secs. 15 and 16. See Tawanda Hondora, “Media Laws in Zimbabwe.” 19 Criminal Law (Codification and Reform) Act, 2004, art. 31. Sleight of Hand 10