14 police stations to which they were later transferred. Several other people, including Grace Kwinjeh, one of the MDC leaders Morgan Tsvangirai, and the NCA chairperson Lovemore Madhuku, were severely injured and needed hospitalization. Amnesty International believes that the repeated blocking of peaceful gatherings and arrest of women human rights defenders by the government of Zimbabwe, through the police, constitute a violation of the rights of women human rights defenders to peaceful assembly and freedom of association. Zimbabwe is a party to the International Covenant on Civil and Political Rights (ICCPR) which recognizes the rights to peaceful assembly and freedom of association provided for in Articles 21 and 22 of the ICCPR respectively. The right to freedom of association in Article 22 of the ICCPR protects the right to form political parties, trade unions and private associations such as non-governmental organizations, including human rights organizations. States party to the ICCPR must also ensure that the right to peaceful assembly is guaranteed on the strict conditions of the Covenant, and that limitations on its exercise do not exceed those expressly laid down in Article 21. This means, in particular, that rules requiring prior permission for the holding of assemblies or demonstrations or any other rules or requirements governing the holding or conduct of public assemblies must be limited to those necessary in a democratic society for the legitimate purposes enumerated in Article 21. A wholesale ban on demonstrations for reasons such as public safety and national security is not compatible with freedom of peaceful assembly as guaranteed by Article 21 of the ICCPR. Zimbabwe is also a party to the African Charter on Human and People’s Rights (hereafter referred to as African Charter). The African Commission on Human and Peoples’ Rights (ACHPR) has also recognized that limitations on the exercise of the right to freedom of association, recognized in Article 10 of the African Charter, must not undermine the fundamental human rights and freedoms guaranteed by national constitutions or international legal standards. Another regional instrument, the ACHPR’s Kigali Declaration, explicitly recognizes the important role of civil society organizations, and human rights defenders in particular, in the promotion and protection of human rights, and calls upon all member states to protect them and encourage their participation in decision-making processes.(63) In interpreting the obligations of states under the ICCPR, the UN Human Rights Committee (HRC) has stated that the right to participate in public affairs, recognized in Article 25 of the Covenant: "[R]equires the full enjoyment and respect for the rights guaranteed in articles 19, 21 and 22 of the Covenant, including freedom to engage in political activity individually or through political parties and other organizations, freedom to debate public affairs, to hold peaceful demonstrations and meetings, to criticize and oppose, to publish political material, to campaign for election and to advertise political ideas."(64) Moreover, the HRC recognizes that the right to freedom of association "including the right to form and join organizations and associations concerned with political and public affairs" is an essential element of the rights protected by Article 25 of the ICCPR. Excessive use of force encouraged within the police force Amnesty International notes that there appears to be a strong conviction within the police force that it is legitimate to use violence against human rights defenders as a form of punishment for criticising government and as a way of intimidating them so they will refrain from engaging in further criticism. Senior officers within the ZRP have failed to denounce criminal conduct which constitutes human rights violations by the police, particularly beatings, torture and other forms of inhuman and degrading treatment of detainees at police stations. This appears to be interpreted as tacit approval by lower ranks within the police force, who perpetrate ill-treatment of human rights defenders. Police authorities fail to investigate and hold accountable junior officers who commit human rights violations against human rights defenders during arrest and while in police custody. A report released in May 2007 by the ZRP states: There is no doubt that the mushrooming of multifaceted western sponsored politically aligned non-governmental organisations, masquerading as champions of democracy, human rights and good governance, are simply there to peddle the regime change agenda meant to dislodge a democratically elected government through such futile attempts as the Save Zimbabwe Campaign.(65) One of the outcomes of such public statements has been the use of excessive force by police to break up peaceful gatherings or marches organised by women human rights defenders. Excessive force has been used in circumstances where protesters were complying with police orders or were not resisting arrest; this