From the above definition it is clear that although “excessive force” is not subject to a precise definition, it is generally use of force beyond the force a reasonable and prudent law enforcement officer would use under the circumstances. Excessive force by law enforcement officers is a violation of a person's rights. The unleashing of police dogs on and falanga on some Complainants are examples of excessive force that was used by the police amounting to a case of Police Brutality. 9.2 Right to Privacy 9.2.1 The findings reveal that the police entered into the homes, premises and property of some of the Complainants without their permission, thereby violating their right to privacy which protects them from arbitrary searches of their homes and unlawful entry into their home, premises or property under section 57 of the Constitution. 9.3 Right to Personal Liberty 9.3.1 The facts reveal that the police targeted the men in the Komboniyatsva residential area merely due to its proximity to the Chiremba turnoff bus stop yet interviews with most stakeholders in Epworth revealed that the touts who were gathered at the bus stop, blocking the road, on the 4th of July 2016 came from different areas. To conclude that every single men in Komboniyatsva had been involved in the commotion at the bus stop and to proceed to conduct a door to door search for and arrest men on this basis led to a violation of personal liberty of men who had not been involved in the incident, including boys below the age of 18 years. In the case of STAMBOLIE V COMMISSIONER OF POLICE 1989 (3) ZLR 287 (S) it was held that the onus is upon the person making the arrest to prove that the arrest was lawfully justified. Further it was held in the case of MUYAMBO V NGOMAIKARIRA AND OTHERS (HC 5195/09) [2011] ZWHHC 138 (07 JULY 2011) that; In order to establish the lawfulness of an arrest without a warrant, the onus lies upon the defendant to show probable cause or reasonable suspicion. In exercising the power of arrest, he must act as an ordinary honest man would act, on suspicions which have a reasonable basis, and not merely on wild suspicion. The arrestor must act on such circumstances as would ordinarily lead a reasonable man to form the suspicion that the arrestee has committed an offence. It is not the function of the police to arrest at Page 31 of 37