social welfare organisations shall be allowed to render such assistance as might be required ”. Whilst laudable in the attempt to address the problem, this general statement says nothing about the scale of the problem, the deliberate suffering inflicted, and certainly nothing about restitution, or compensation. 6.2 Widespread violations The second feature that must be present, if the allegation about crimes against humanity is to be sustained, is that the violations must be widespread, as the quote below illustrates: The term ‘widespread’ requires that there is “massive, frequent, large scale action carried out collectively with considerable seriousness and directed against a multiplicity of victims.” 47 As was seen from the data on 2008, the violence was clearly widespread in several ways: it was spread right across the country, with reports from all Provinces and many different Districts; it was clearly frequent, with violations reported in all three months (and also in June 48); and was large scale, with very large numbers of victims reported, although exact estimates are not possible.49 As regards the last, the cases reports indicate very large numbers of people involved in the violations, so it is evident that there has been planning. As indicated above, violence was reported from many different Provinces, with some Provinces reporting much higher frequencies of violations, and, interestingly, the same Provinces implicated in 2002. Although it is not possible to give exact numbers of victims – only a nationwide investigation could do this – the numbers are very large, with the ZPP report estimating 16,400 cases since January, with over 90% coming from the period since March 2008. Thus, there is considerable prima facie evidence to substantiate the claim that the violations since March 2008 have been widespread, and, furthermore, that the pattern observed has been evidenced in the recent past, as was shown in the comparison with the alleged violations in 2002. This on its own should be enough to warrant investigations of crimes against humanity, but the claim is strengthened further by the demonstration that the violations have been “systematic”. 6.3 Systematic violations As was pointed out earlier, “systematic” has a straightforward definition: The term ‘systematic’ refers to the “organized nature of the acts of violence and the improbability of their random occurrence.” 50 47 See again ICTR, Prosecutor v. Akayesu, ICTR-96-4-T, Trial Judgment and Sentence, 2 September 1998, para. 580; ICTY, 48 See again See Solidarity Peace Trust (2006), Desperately Seeking Sanity: What Prospects for a New Beginning in Zimbabwe? 29 July 2008. DURBAN: SOLIDARITY PEACE TRUST; ZPP (2008), Run up to 27 June 2008 Presidential Run Off Election. July 25, 2008. HARARE: ZIMBABWE PEACE PROJECT. 49 50 Prosecutor v. Blaškic, IT-95-14, Trial Judgment, 3 March 2000, para. 206. The Zimbabwe Peace Project estimated 16,400 cases since January 2008, which is not a trivial number. See again ICTY, Prosecutor v. Kunarac, IT-96-23-T, Trial Judgment, 22 February 2001, para. 429.