pardon or commute sentences for those who would have been found guilty thus dampening the spirits of those who would have won cases against perpetrators of human rights violations. Besides going against the tenets of its domestic law and breaking human rights principles, Zimbabwe has been going against its own obligations according to the international treaties it has signed and ratified such as the International Covenant on Civil and Political Rights (ICCPR). Article 2(3a) of the ICCPR obliges state parties to undertake measures 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”. It is clear that Article 2(3) does not provide a right in individuals to force a state to investigate, and thereafter to prosecute any suspects who have been convincingly identified.⁴⁷ However, the HRC has said 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”.⁴⁸ The Police Act as a stumbling block towards holding officers accountable In one way the Police Act [Chapter 11:10] is progressive as it sets out what can be defined as crimes if police officers were to deviate from the law. However, what the Police Act gives with the right hand, it takes away with the left. The Police Act in subsequent sections after having defined the offences goes further and gives very ubiquitous regulations which are difficult to discern whether they should be held as ways of placating the police force or trying to enforce discipline. The Police Act Schedule sets offences for the police force as follows: · · · · · · 11: Without good and sufficient cause, disobeying or refusing or omitting or neglecting to carry out any lawful order, written or otherwise. 19: unnecessarily detaining any person in custody. 21: Using unnecessary violence towards, or neglecting or in any way ill-treating any person in custody or other person with whom he may be brought into contact with in the execution of his duty” 25: Without authority, communicating directly or indirectly, to the press or to the public any matter or thing concerning the Police Force, the communication whereof results in or is reasonably likely to result in any prejudice to the administration, discipline or efficiency of the Police Force. 28: (1) Willfully or negligently losing, destroying, injuring or damaging any property … of any person in custody, or any exhibit in a criminal case or property, lost, found, taken for safe keeping or unclaimed. 34: Omitting or neglecting to perform any duty or performing any duty in any improper manner. The provision marked as Section 11 above presents challenges in identifying what would be regarded as lawful orders as opposed to criminal acts by the police. These provisions reveal the challenge and the need to prosecute rogue police officers who violate the law and policies governing the police. For a long-time the police has been controlled by the ZANU-PF government, intricately connected with the country's politics, and under orders to obey whatever laws or instructions given by superiors. The ⁴⁷ For a comprehensive and incisive discussion of this matter see C Jalloh and A Marong, “Ending Impunity: The Case for War Crimes Trials in Liberia‟, (2005) African Journal of Legal Studies 53 at 62 – 64. ⁴⁸ 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). 24 Anti-Impunity Report