shortly after Gubbay’s resignation)32 and Justice Ishmael Chatikobo (who came under pressure after ruling in favor of a private radio station. President Mugabe later issued a presidential decree overturning his ruling and banning the radio station).33 Justice Sandra Mungwira went into exile after acquitting three MDC activists accused of murder.34 Justices Ahmed Ibrahim, James Devittie and Nick McNally were also forced into exile after receiving threats of violence when they accused the government of undermining the judiciary.35 In 2004 Justice Michael Majuru fled into exile and faxed his resignation after he was publicly criticized and threatened with investigation by the government when he ruled in favor of an independent daily newspaper that the government had banned.36 Since 2000 the government has appointed to the bench judges with previous connections and known sympathies to ZANU-PF. To ensure their loyalty, the government allocated land seized under its controversial land reform program to judges. According to Eric Matinenga, a former judicial officer and MDC member of parliament who carried out an extensive study of the judiciary in Zimbabwe, up to 95 percent of judges have been allocated farms that were forcibly seized from white commercial farmers.37 A lawyer based in Harare told Human Rights Watch: Information on how government allocated farms seized from commercial farmers is not readily available, but l know that an overwhelming majority of judges received farms from government.38 Another lawyer told Human Rights Watch: 32 Hativagone Mushonga, “Mugabe Moulds Pliant Judges,” Institute of War and Peace Reporting, May 31, 2006, http://www.iwpr.net/?p=acr&s=f&o=321302&apc_state=heniacr2006 (accessed November 5, 2008). 33 Ibid. 34 Ibid. 35 Ibid. 36 “Zimbabwe judge quits, goes into exile,” The New Zimbabwe, January 29, 2004, http://www.newzimbabwe.com/pages/majuru.1373.html (accessed November 5, 2008). 37 Human Rights Watch interview with Eric Matinenga, Harare, August 29, 2008. 38 Human Rights Watch interview with lawyer, Harare, August 29, 2008. 15 Human Rights Watch November 2008