NPRC.’ The NTJWG further encouraged the Government to ensure that there is adequate funding for the NPRC. On 15 February 2019, the Zimbabwe Lawyers for Human Rights (ZLHR) approached the High Court of Zimbabwe on behalf of one of the victims of violence, seeking to extend the lifespan of the NPRC so that it operates for 10 years as envisaged by the relevant Constitutional provision. The judgment had not yet been handed down by the time this report was compiled. 2.2 The Independent Complaints Mechanism (ICM) a. Establishment of the ICM Section 210 of the Constitution provides for the establishment of an Independent Complaints Mechanism (ICM) for receiving and investigating complaints from members of the public about misconduct on the part of members of the security services, and for remedying any harm caused by such misconduct. Almost six years since the Constitution came into operation; this section has not been implemented. b. Violation of the Constitution Section 324 of the Constitution states that all constitutional obligations must be performed diligently and without delay. By not bringing to Parliament the Independent Complaints Mechanism Bill, government is in breach of section 324 of the Constitution. Implementing Section 210 will go a long way towards dismantling impunity and holding perpetrators to account. This has been made more urgent by the continued violations of human rights by security forces. On 1 August 2018, the Zimbabwe National Army (ZNA) opened live ammunition on unarmed civilians killing at least 6 people and injuring 4 hundreds. Between 14 January and 5 March 2019, ZNA and the Zimbabwe Republic Police (ZRP) again shot and killed unarmed civilians. The Zimbabwe Human Rights NGO Forum (the Forum) reported that 17 people lost their lives in the violence. It is this continued violation of human rights by the security forces which makes it urgent for the establishment of the ICM. c. Interventions by Civil Society In the absence of an official mechanism to deal with violations of human rights by security services, civil society is stepping into the gap. Members of the public have been part of this push for accountability by reporting all violations of human rights by the security forces. During the shutdown, the Forum received dozens of reports against the security forces. By the time of this update, the Forum has since issued at least thirty (30) Notices of Intention to sue the State for the unlawful actions of the military and police during August 1 2018 post-election violence and the stay away which took place from the 14th of January 2019. The notices have been issued in terms of Section 6 of the State Liabilities Act (Chapter 8:14). All the thirty (30) legal suits have raised various misdemeanours, including wrongful deaths, torture and other forms of cruel, inhuman and degrading treatment, assault, deprivation of liberty and alleged theft by the police and army. Several of these victims sustained injuries to the body and suffered damages in the form of loss of support and medical expenses. While members of the security forces appeared to be acting within the course and scope of their employment when they STATE OF TRANSITIONAL JUSTICE IN ZIMBABWE 2018 REPORT NATIONAL TRANSITIONAL JUSTICE WORKING GROUP ZIMBABWE