Judgment No. CCZ 9/2016 17 Const. Application No. CCZ 316/2012 Collection of the payment of the obligation imposed on those who are in possession of receivers is imposed on the ZBC as an obligation. When the ZBC and its appointed agents demand, in appropriate circumstances, production of a listener’s licence from a citizen, they are discharging a legal obligation. Collection is in aid of revenue. It occurs after the obligation to pay the money fixed by the ZBC in terms of the Act has been imposed. Collection has no relevance in the determination of the question whether the obligation to pay the money is a tax or not. The requirement that the money collected as payment of licence fees should be paid into the general funds of the ZBC and not into the Consolidated Revenue Fund is consistent with the provisions of s 101 of the Constitution. The earmarking of the money for payment into the general funds to be used as revenue by the ZBC to meet the costs of its operations underscores the intention to protect the financial independence of the ZBC. State revenue cannot be earmarked except at the point of expenditure by appropriation. The section provides: “101 Consolidated Revenue Fund, All fees, taxes and other revenues of Zimbabwe from whatever source arising, not being moneys that – (a) are payable by or under an Act of Parliament into some other fund established for a specific purpose; or (b) may by an Act of Parliament, be retained by the authority that received them for the purpose of defraying the expenses of that authority; shall be paid into and form one Consolidated Revenue Fund.” In the first place it may be admitted that revenue is essential to the effective operation of the public broadcasting service and the existence of the ZBC. The State used its power to provide the ZBC with a reliable source of funding to enable it to properly fulfil its statutory obligations. The money received constitutes the proceeds of the discharge of the