limitations or prescription. Many of the difficulties relating to criminal prosecutions of perpetrators apply mutatis mutandis to the bringing of civil actions against them, as do some of the arguments in favour of court proceedings. Clearly, judiciallybased compensation is important, but inherently problematic. Civil society needs to understand the existence of the real constraints without abandoning the strategic use that can be made of this method. As a necessary aside it should also be noted how in periods of economic chaos and hyper-inflation such as presently being suffered in Zimbabwe, the claiming and payment of civil damages can become an almost meaningless exercise. Another issue which has been mentioned already and which relates to the weakness of litigation damages is the difficulty in suing perpetrators when the state has taken deliberate steps to disguise their identity. On the positive side innovative use can be made of class-actions. What needs stressing is that all of these forms of reparation deserve equal recognition, although their applicability will vary from victim to victim, perpetrator to perpetrator, and country to country. Further practical considerations, based in international law but which will unfold in the wider socio-political context, arise from the clearly established rule that the State of Zimbabwe as well as the individual perpetrators have an obligation to provide these recognized forms of reparation. The Summary’s practical call, therefore, for the Government to establish a reparations 43 fund for victims, is firmly rooted in both law and principle, and is an extremely important concept which civil society needs to develop. Whether it wishes to or not, a successor Government cannot legally shirk its responsibilities to victims of the previous regime or regimes. Ways must also be found to recover the illgotten gains of perpetrators to boost such a fund. Zimbabwe’s civil society has a tremendously onerous task ahead. It must struggle to maintain the invaluable programmes it has 43 (Appendix II), p. xiii. 35