education specified in subsection (1), provides voter education under the guise of providing it as part of a course in law or civics or any other subject for students at an educational institution”. This has the potential, even if remote, of interfering with academic freedom under which academics in institutions of learning should be unrestricted in the execution of their duties. It is highly unlikely that academics providing courses that include elements that would otherwise fall under the heading of higher education would be liable under this provision however; it presents an unnecessary risk of harassment if applied unreasonably by law enforcement agencies. This is particularly relevant in the Zimbabwean context where education providers, including teachers and academics have occasionally suffered harassment in their institutions. Commission’s Power to give Directions • Under section 40E, the Commission has the power to monitor the provision of voter education by other persons. The Commission may by written notice give directions to every person responsible for providing and publishing the programme to cease providing or publishing it or to make such alterations to it as the Commission may specify to render it accurate and fair. This power is exercisable where “the Commission considers that any programme of voter education is— (a) false, in that the information provided by it is materially false or incorrect; or (b) misleading, in that while the programme purports to be impartial it is materially and unfairly biased in favour of or against a political party or candidate contesting the election” • However, any person affected by any proposed direction is entitled to be heard before such direction is issued, which essentially complies with a basic rule of Natural Justice and indeed the Constitution which under Section 18 guarantees the protection of the law. Foreign Funding 19