police officers can be held accountable. If the Commissioner General has powers to rescind or alter sentences then it means that police officers acting outside the law but obeying his orders can do so knowing full well that they are protected by the “law”. Arguments can be made that such a provision should be read with positivity, however judging from what the Forum has observed in its interactions with the police and other state security agents it would be difficult to have confidence in a police force that has wide powers of “self-control” outside the normal judicial system of the country. Zimbabwe's laws remain weak with regards a most fundamental issue linked to police brutality, excessive use of force, and extrajudicial killings. Members of the police force have on numerous occasions been implicated in cases that have ended up being judged to have been extra judicial killings³³ due to recklessness, complete disregard of the law and a “trigger-happy” mentality. On the question of use of lethal force by the police, including in the context of arrest, this matter should be viewed as a matter of utmost gravity and should be based on a solid ethical and legal framework. These include the fundamental nature of the right to life; the irreversible nature of death; the potential of errors of fact and judgment; the effect on the legitimacy of the police and the State; and the trauma suffered by everyone involved when a life is ended unlawfully through violence”.³⁴ A Rights-Based Approach to Zimbabwe's Legal Obligations Under international human rights law standards, the Zimbabwe government has legal obligations to respect, protect, and fulfill the enjoyment of human rights by all those under its jurisdiction. The obligation to respect human rights requires the government and all its organs including the ZRP, ZNA and the CIO, to refrain from carrying out any discriminatory and retrogressive practices or sponsoring or tolerating any practice, policy or legal measures that violate the rights of individual citizens. With regards the human rights violations perpetrated by the security agents highlighted in this report, the government is required to refrain from such acts. Concurrently, the obligation to protect the right to freedom from torture and any other violations by state security agents obliges the state and its agents to prevent the violations by any other individual or non-state actor who might include private individuals such as medical personnel, transport operators, bankers and other such institutions as might be involved in perpetuating human rights violations by state security agents. The obligation to fulfill means that States must take positive action to facilitate the enjoyment of human rights. ³³ 295/04 Noah Kazingachire, John Chitsenga, Elias Chemvura and Batanai Hadzidzi (represented by the Zimbabwe Human Rights NGO Forum) / Zimbabwe – ACHPR. ³⁴ Ibid at para 108 Anti-Impunity Report 17