later charged with misconduct by the Supreme Court’s chief justice. At time of writing the judge’s misconduct case was pending consideration by President Mugabe. On March 8, 2013, in Harare, police charged Jestina Mukoko, director of the Zimbabwe Peace Project, with leading an unregistered organization under the Private Voluntary Organization (PVO) Act, and with smuggling radios and mobile phones into the country in violation of the Broadcasting Services Act and the Customs and Excise Act. The charges under the PVO Act violate the right to freedom of association, while the other charges appear to be a politically motivated attempt to curtail the group’s human rights work. On February 13 and 14, police in Harare and Bulawayo forcibly disrupted the annual Valentine's Day "love" protests by about 190 members of Women of Zimbabwe Arise (WOZA). The police arrested, detained and in some cases beat with batons protesters, including the WOZA national coordinator, Jenni Williams. The protesters were released without charge following the intervention of lawyers. On February 11, in what appears to have been coordinated action, police raided the offices of the National Association of NGOs (NANGO) and Community Tolerance Reconciliation and Development (COTRAD) in Masvingo and the Zimbabwe Peace Project (ZPP) offices in Harare. On March 8, the ZANU-PF-controlled Zimbabwe Electoral Commission (ZEC) announced that any civil society organization under police investigation would be barred from monitoring the constitutional referendum and elections. This directive would directly affect the main civil society organizations operating in the country, including ZPP, Zimbabwe Human Rights Association (ZimRights), Zimbabwe Election Support Network, and Crisis in Zimbabwe Coalition. The recent police actions against civil society groups appear to have had the approval of the highest levels of the police. At the Senior Police Officers’ Conference in November 2012, attended by country’s top police officers, an official statement was approved noting “with THE ELEPHANT IN THE ROOM 26