Zimbabwe Rule of Law Journal |167 Section 97 of the constitution of Zimbabwe prescribes the legal standard and procedural requirements for removal of the President and in so doing it provides means by which the President may be held accountable; three of which are: a) Serious misconduct b) Failure to obey, uphold or defend this constitution c) Wilful violation of this constitution The fact that there exist grounds of removal for the President in the constitution reinforces the principle highlighted in the Nkandla judgment that the President is a subject and creature of the constitution; indeed it is the constitution which dictates how the President may come into office, how the President may or must leave office, and the conduct of the President during the tenure in office as President. The constitutional court in the case of the President of the Republic of South Africa v Hugo described the President as follows; “Ultimately, the President as the supreme upholder and protector of the constitution is its servant. Like all other organs of State, the President is obliged to obey each and every one of its commands”.20 However, the grounds for removal regarding the reference to “serious misconduct” of the President (s 97) is, at best, open-ended and provides little clarity as to what those particular grounds actually constitute. Does it refer to specific criminal acts, neglect of official duties, or generally conduct which undermines the integrity of the office of the President? At the same time it may also be argued that defining the grounds of removal is not necessary because allegations of constitutional violations will generally be based on the circumstances and that it is the courts which will then make its finding after assessing the circumstances of the particular violation alleged to have been committed. Is s 97 in itself sufficiently embodied to hold the president of Zimbabwe accountable in the same manner that the South African 20 [1997] ZACC 4; 1997 (4) SA 1 (CC); 1997 (6) BCLR 708 (CC) at para 65