56 | Zimbabwe Rule of Law Journal states that the funds of the Judicial Service shall consist of moneys appropriated by Act of Parliament for the salaries and allowances payable to and in respect of members of the Judicial Service and the recurrent administrative expenses of the Judicial Service. Funds of the JSC also include any donations, grants, bequest made to the Judicial Service and accepted by the Commission with the approval of the Minister. These provisions raise the question on whether the courts will be independent if the JSC and the courts rely on the state for financial resources. However, it is important to point out that the JSC has a duty to approach the state for adequate funding for salaries and administration costs. 3. General challenges faced by the Judicial Service Commission The JSC is now an established constitutional body, having existed since 1987. As with many other Commissions and constitutional bodies aimed at safeguarding democracy and the rule of law, it continues to face many challenges ranging from the limitations of financial resources and human resources, among others. 3.1 Financial resources The lack of adequate financial resources for the JSC has affected the effective and efficient administration of justice. Most administrative issues which the JSC deals with require funding and these include construction of courts, stationery, recording equipment, libraries, transcribers, computers, transport and furniture. Many of the Magistrates Courts in Zimbabwe, except the regional magistrates, lack basic modern technology such as desktop computers. This affects their research capacity given the current worldwide reliance on internet and online sources of legal data. Further, case management has also been a major problem at both the High Court and Magistrates Courts where court records have been known to occasionally disappear.81 Generally, if the state is failing to provide adequate funds to the JSC it means that it is failing to fulfill its duty in terms of Section 164(2)(b) which requires the state to assist and protect the courts to ensure their independence, impartiality, dignity, accessibility and 81 This was again confirmed by Chief Magistrate Guvamombe who stated that “because of manual filing we sometimes lose records or take time to locate them, thus delaying court proceedings; see Zimbabwe jobs freeze puts pressure on country’s judiciary, The Independent, March 21, 2014. http://www.theindependent.co.zw/2014/03/21/zimbabwe-jobs-freeze-putspressure-countrys-judiciary/