allegiance to President Robert Mugabe, as well as to promise that I would not disclose my ordeal, either to the independent press or the courts. 17. Around 19:30 pm, I was blindfolded and taken to Harare Central Police Station, where I was booked into a horrendously inhumane holding cell. On the third day of my arrest, my lawyers, who had at that point obtained a High Court injunction ordering my release to court were allowed access to me. I had not had food nor water throughout the period of my detention. I had also not been formally notified of the nature of the charge against me. Subsequently, however, I was charged under Section 5 of the Public Order and Security Act, which deals with organising, planning or conspiring to overthrow the government through unconstitutional means. These charges were dismissed in a court of law. 18. At present, I have fled the country in fear for my life, having been threatened with death by some of those who tortured me. In spite of psychiatric and other medical treatment, I however continue to experience physical pain, nightmares, as well suffer depression. I am told and verily believe that what the State of Zimbabwe did to me, not only contravenes international law, but also offends against its obligations thereunder. In particular, I believe that torture constitutes a crime against humanity and as such, the authorities in Zimbabwe, under the leadership of President Robert Mugabe, should be held accountable. 19. It is my sincere belief that my torture and ill treatment was authorised and condoned at the highest level of the Zimbabwe state. It is inconceivable that President Mugabe is unaware that his police, army and intelligence officials are using torture. The President has been aware that torture is being used against human rights activists and those suspected to be linked to the MDC, as is exemplified by the case of Mark Chavhunduka and Ray Choto. Nevertheless, he is taking no discernible steps to either condemn or stop the use of torture. 20. I lodged a report of what transpired with the police, but up to now no action has been taken. I have also instructed my lawyer institute civil proceedings, but am not hopeful as I the judicial system has been largely subverted by the executive. Furthermore, the police are notorious for defying court orders. 21. I make the above believing same to be true to the best of my recollection. Wherefore, I pray: A) that the Government of Zimbabwe be ordered to respect and abide by its international obligations; B) that the Government of Zimbabwe be ordered to pay damages occasioned as a result of the arrest and torture and C) that individuals responsible, including President Robert Mugabe, in his official capacity, the Minister of Home Affairs, Kembo Mohadi, the Minster of State Security, Nicholas Goche and the Commissioner of Police, Augustine Chihuri , be brought to account for torture and other crimes against humanity. Signed on this ………..day of September 2003. …………………………………………………….. Gabriel Shumba Before Me………………………………………… Commissioner of Oaths 88