GPA, in which the signatories agreed that it was the duty of all political parties and individuals to (a) respect and uphold the Constitution and other laws of the land; [and] (b) adhere to the principles of the Rule of Law. Nature of violations There were instances of manipulation of court and penal system processes through interference by the Executive, non-compliance with judgments, and openly partisan approaches from some justice officials in favour of ZANU(PF). Legal practitioners were denied access to their clients, logistical challenges (e.g. transport shortages to and from remand prisons) were used to justify delays in the trial process, and torture was used to extract confessions. Non-disclosure of suspects’ whereabouts was used to isolate suspects or victims from their lawyers and the public. The independence of the judiciary was severely compromised through political interference, partisan appointments and political patronage. Case history • On 6 May, Constance Gambara, the clerk for a High Court Judge, Justice Chinembiri, Bhunu, was arrested by police with her nine-month-old baby for criminal abuse of public office after she typed, in line with her professional duties, the warrant of release for 2008 abduction victims Chris Dhlamini, Ghandi Mudzingwa and Andrison Manyere. 4.3 Violations of expression and assembly rights Rights violations relating to freedom of expression, media rights, access to information, and freedom of assembly and association. 4.3.1 Violations of freedom of expression Repressive and punitive measures in conventional quests for the right to express, seek, receive or disseminate information and ideas. Policy The Criminal Law (Codification and Reform) Act (‘Criminal Law Code’) and POSA criminalize utterances likely to undermine police authority (Criminal Law Code, section 177), or insulting the office or person of the President (Criminal Law Code, section 33). Section 177 of the Criminal Law Code serves to cause individuals and organizations to censor themselves. In attempting to address limitations to freedom of expression, article 12 of the GPA on Freedoms of Assembly and Association, recognized ‘the importance of freedoms of assembly and association’, and noted that public meetings ‘have to be conducted in a free, peaceful and democratic manner’. The parties also agreed to work together in a manner that guaranteed ‘the full implementation and realization of the right to freedom of association and assembly’. 16 Zimbabwe Human Rights Report – 2009