Farm workers have continued to be the victims of violence during farm occupations. Violence against farm workers is linked to the support given to the MDC by commercial farmers and by perceived implication, by their workers too. In many areas, it seems that farm workers have been targeted for violence both so that the assailants could take over their homes and in order to deprive the white farm owner of numerous potential allies who have a stake in keeping their jobs and might therefore support the farm owner in resisting government policy. Weaknesses in the organizational representation of farm workers have also made them vulnerable to assault and intimidation.38 Perpetrators of Property Rights Violations Major perpetrators of violence include the war veterans, the army, police, senior civil servants (in their individual capacities or as agents of the state), ZANU PF militia, traditional leaders, and, in some cases, common criminals. The common thread among all these peoples' actions was that crimes were committed in the name of the revolution, the “Third Chimurenga” and in the majority of cases, violence was committed with impunity. By the end of 2009, many actors were responsible for property violation, from ordinary peasants to highranking politicians, the 'junta'39 and government ministers and even included ministers of religion. Some did it overtly while others chose to carry out violence secretly. All in all this violence, which disrupted the once vibrant agricultural economy, had long-term effects materially and psychologically. Judicial decisions on cases brought to court in Zimbabwe including the role of the Commissioner of Police and right of everyone to protection of the law Farm invasions were illegal and are often riotous. It is incumbent upon the police to protect the farmers and their workers and further to investigate and arrest perpetrators of crimes on the farms. Under international law the right to access justice and enjoyment of effective remedies on infringement of property rights is recognized. Section 18 of the Constitution of Zimbabwe stipulates that everyone is entitled to the protection of the law - in apparent conformity with international law. But has everyone and in particular the commercial farmer and the farm worker enjoyed the protection of the law? The role of the police was succinctly described in Chavhunduka and Anor v Commissioner of Police and Anor.40 The entitlement of every person to the protection of the law which is proclaimed in S18 (1) of the Constitution embraces the right to require the police to perform their public duty in respect of law enforcement. This includes the investigation of a crime, the arrest of the perpetrator provided the arrest so warrants and bringing him or her for trial before a court of competent jurisdiction. As underscored in Commissioner of Police v Rensford and Another,41 a member of the police may not refuse to perform a duty imposed on them by the law of the land. The protection of the law and the police duty in that regard, under S18 (c), extends to protection in respect of a person's civil rights. When the farm invasions started, the Commissioner of Police washed his hands of the matter, stating that the hands of the police were tied and they could not act since the matter was political. The CFU won three High Court orders in 2000 forcing the police to remove the illegal farm occupiers and restore law and order. On 17 March 2000, in CFU v the Minister of Agriculture Land and Resettlement 42 Justice Paddington Garwe declared that the invasions were illegal and ordered the Commissioner of Police to evict the unlawful occupiers from the land within twenty-four hours. The Commissioner appealed against the order stating that the state had no resources to carry out the evictions. Justice Chinhengo dismissed the appeal and upheld Justice Garwe's order stating that the Commissioner of Police had a clear duty to enforce the consent order, and to afford commercial farmers the protection of the law enshrined in the Constitution. Despite these two judgements, the leaders of the war veterans publicly proclaimed that they would not be bound by the court order, but instead would intensify the farm occupations. 38 Human Rights Watch, 2001 In Zimbabwe, when the army became political and got involved in the political processes, it was sarcastically called 'junta'. The term does not mean that there was a praetorian government in Zimbabwe at one given time. 40 2000(1) ZLR 418(S) losses suffered by commercial farm workers in Zimbabwe between 2000 and 2008. Report prepared by the Research andAdvocacy Unit (RAU)? December 12, 2008 41 1984 (1) ZLR 202(S)At 202 H 42 See CFU vs. Minister of Agriculture Land and Ressettlement (HC3985/2000) 39 11