Taking from Mendez's analysis outlined above, there is reason to believe that international law supports other accountability mechanisms as opposed to solely criminal prosecutions.¹⁷ Zimbabwe could borrow from such progressive policy thinking when it comes to its policies on dealing with a past littered with reports of human rights violations. International law and curbing impunity The need to hold systematic human rights violators accountable is well established in international law. Article 2 (3a) of the International Convention on Civil and Political Rights (ICCPR) obliges state parties to undertake to ensure that victims of human rights violations “shall have an effective remedy, notwithstanding that the violation has been committed by persons acting in an official capacity”. The UN Human Rights Committee (HRC) - the interpreter of the ICCPR, has repeatedly held that blanket amnesty laws and pardons are inconsistent with the ICCPR because they create “a climate of impunity‟ and deny the victims this right to a remedy”. ¹⁸ Article 9 of the ICCPR guarantees the right to liberty and security of the person as a right to be guaranteed by the state. Subsection 5 of the article gives a victim a right to compensation where his or her right to liberty and security has not been realized by the state. The right to a remedy or reparation in the event of a human rights violation is well entrenched in international law. The Articles on Responsibility of the State for Internationally Wrongful Acts prepared by the International Law Commission, the Universal Declaration of Human Rights (UDHR), the ICCPR provides a right to an effective remedy and compensation. The Velasquez Rodriguez¹⁹ is instructive and the judgment ruled that “every violation of an international obligation which results in harm creates a duty to make adequate reparations”. In Embga Mekong Louis v Cameroon case,²⁰ the African Commission on Human and Peoples Rights granted compensation to the legal heirs and next of kin of a deceased victim for human rights violations. Zimbabwe and its relationship with international law In Zimbabwe international law is not automatically applicable or made into local law when ratified or acceded to. For international law to become applicable in Zimbabwe it should be incorporated through an Act of Parliament.²¹ The relevant treaties creating binding legal obligations on human rights standards relevant to policing in Zimbabwe are the ICCPR, the ICESCR, and the African Charter on Human and Peoples' Rights (ACHPR). They have all been ratified by Zimbabwe without reservations. Among other international treaties and conventions of International law, Zimbabwe is signatory to both the ICCPR²² and the ICESCR,²³ of which it ratified on 13 May 1991. Apart from these Zimbabwe is also a signatory to the Rome Statute²⁴ but has not ratified it. Zimbabwe is also party to the Constitutive Act of the African Union, the Charter of the African Commission on Human and Peoples Rights as well as other regional protocols in the Southern Africa Development Community organization. ¹⁷ P DeGreiff, “International Courts and Transitions to Democracy”, (1998) 12 Public Affairs Quarterly 79, at 79. ¹⁸ Comments of the Human Rights Committee, Consideration of Reports submitted by States Parties under Article 40 of the Covenant, 10 UN. Doc. CCPR IC/79/Add.46 (1995). ¹⁹ Velasquez Rodriguez Case, Inter-Am. Ct.H.R. (Ser. C) No. 4 (1998), Inter – American Curt of Human Rights (IACrtHR), 29 July 1998, available at http://www.refworld.org/cases, IACRTHR,40279a9e4.html [accessed 7 November 2018] ²⁰ Embga Mekongo Louis/Cameroon 59/91, available at http://www.achpr.org/communications/decision/59/91/ [accessed 7 November 2018] ²¹ S327 (2) (a) and (b) of the Zimbabwe Constitution ²² International Covenant on Civil and Political Rights (adopted 16 December 1966, entered into force 23 March 1976) 999 UNTS 171. ²³ UN General Assembly, International Covenant on Economic, Social and Cultural Rights, 16 December 1966, United Nations, Treaty Series, vol. 993, p. 3, available at: http://www.refworld.org/docid/3ae6b36c0.html [accessed 25 April 2018] ²⁴ N General Assembly, Rome Statute of the International Criminal Court (last amended 2010), 17 July 1998, ISBN No. 92-9227-227-6, available at: http://www.refworld.org/docid/3ae6b3a84.html [accessed 25 April 2018]. 14 Anti-Impunity Report