THE CASE OF HENRY DOWA knowingly or negligently breach this requirement - something needs to happen in addition to the mild sanction of merely bearing the costs of repatriation and replacement.72 For example, a Member State who consistently breaches the rule could be barred from participating in UNCIVPOL. Such a rule would necessitate a proper investigation by the UN where allegations of serious past human rights violations are raised in respect of a serving UNCIVPOL officer, including the right of the UN to send investigators to the Member State concerned if the allegations are disputed. These arrangements would not, of course, be a substitute for all the existing obligations under CAT and other international treaties and international law norms generally, but would be in addition to them. While some Member States might object that this would constitute an unwarranted infringement of their sovereignty, or that political opponents could use it to frivolously undermine a legitimate authority, these arguments are no different to those usually raised in negotiating international agreements, and safeguards can be found to prevent male fide accusations being made for ulterior motives. If the UN adopted a more vigorous approach to the selection of civilian police peacekeepers, it would not only help to ensure higher standards for UNCIVPOL, but it would also send a message to Member States that their domestic police forces should and will be the subject of closer scrutiny if they wish to participate in international operations. Member States such as Zimbabwe would be forced to consider the financial and diplomatic advantages in cleaning up their act, or at least in not brazenly rewarding those individuals who have established reputations for barbarity. Dowa in action back in Zimbabwe This review of the case of Henry Dowa would not be complete without mentioning some of the latest news relating to him since he left Kosovo in September 2003. In October 2003 a Zimbabwe organisation of human rights lawyers said in a statement that he had actively participated in unlawfully preventing lawyers from having access to clients illegally detained in the Law and Order section at Harare Central police station, following a political demonstration in the capital.73 In November 2003 a Zimbabwe press report confirmed that Dowa remained active and had been involved in the arrest of lawful political protesters the previous month.74 It has also been recently alleged that Dowa ordered members of the ZRP Riot Squad to severely beat a detainee, which they did.75 Finally, in December 2003 a Mugabe newspaper carried a report of thirty-six ZRP officers leaving for UN peacekeeping duties in Kosovo, and five heading for Liberia. The Commissioner of Police addressed the police officers as follows: 72 73 74 75 It is presumed that this is what happened in Dowa’s case. Zimbabwe Lawyers for Human Rights, Harare, 22 October 2003: “Human Rights Defenders Under Siege.” The Independent, Harare, 7 November 2003: “Human Rights Violators on the Loose.” Zimbabwe NGO Human Rights Forum, Harare: October 2003 Violence Report. 17