124 | Zimbabwe Rule of Law Journal offence is committed both when the maker intended and realised that there is a real possibility of the prejudicial consequences occurring and even when he or she had no such intention. The prejudicial consequences that occur are these: • promoting public disorder or public violence or endangering public safety; or • adversely affecting the defence or economic interests of Zimbabwe; or • undermining public confidence in a law enforcement agency, the Prison Service of the Defence Forces of Zimbabwe; or • interfering with, disrupting or interrupting any essential service. Implications for second sub-species of Constitutional Court ruling The following rulings by the Constitutional Court pertaining to the undermining public confidence provision would appear to apply with equal force to the provisions on the other prejudicial effects. a) The ruling that the falsity requirement for this offence be confined to a statement that is wholly false. b) The implied ruling that the offence should only be committed if the statement is published to a significant number of persons rather than just one other person. c) This sub-species requires that the maker of the statement must know that the statement is false or not have reasonable grounds to believe that it is true. The ruling of the Constitutional Court requires that the maker of the statement must know that the statement is false. The offence should not be committed if the State proves simply that the maker did not have reasonable grounds to believe that the statement was true. d) To make the maker of the statement liable even where he or she had no intention to cause the prejudicial consequence is to make the maker strictly liable and cuts across the normal principles that there must be a blameworthy state of mind which for serious crimes must normally be intention; it is not sufficient to prove merely that he or she knew he or she was making a false statement.