political parties which qualify for public funding must have received at least 10% of the vote in the election while the threshold in Zimbabwe, as we have already noted above, is 5% of votes cast in the election. In Namibia, public funds are allocated to political parties represented in the legislature in proportion to the votes won by the parties in the previous election. Lesotho and Mozambique take a slightly different approach. In Lesotho half the funds are allocated to registered parties and shared equally amongst them, while the other half is distributed to each party in proportion to the number of candidates fielded. In Mozambique one-third of the funds are allocated to presidential candidates, one-third to political parties in parliament in proportion to the seats held and one-third to parties fielding candidates for parliament in proportion the number of candidates fielded62. It seems generally acceptable that public funding of political parties must be based on some threshold or formula. In United Parties v Minister of Justice, Legal and Parliamentary Affairs and Others, supra, the Supreme Court held that it is justifiable to place a reasonable limitation (own emphasis) upon the payment of State funds to political parties. Such limitation, the Court said, encourages serious political contenders but discourages trifling parties from being established solely in order to secure public funding. It would be undesirable for tax payers’ moneys to be wasted on parties which do not command any meaningful support or which clearly have no prospect of making any meaningful contribution to the growth and consolidation of democracy in the country. The Country Study on Zimbabwe observes that it has “become noticeable in Zimbabwe that a number of small parties emerge during election time” and that these have the effect of confusing the electorate and splitting votes. The study concludes that such parties do not serve to improve democratic principles in the country63. Some countries though, such as Lesotho and Mozambique, disburse funds to political parties participating in an election so that the parties can finance their election campaigns. 62 Ibid. st Country study: “Resuscitating party politics in Zimbabwe: scenarios for the 21 century”: An analysis of the MDC and Zanu-PF from the perspectives of political leadership, political architecture and party constituencies (Author and date?), p.4. 63 24