Research and Discussion Paper on a TJ Framework for Zimbabwe • economic, social and cultural rights, if they are grave and systematic, for example violations taking place on a large scale or targeted at particular population groups. The South African enabling law for the establishment of the Truth and Reconciliation Commission (TRC) defined gross violation of human rights as • • (a) the killing, abduction, torture or severe ill-treatment of any person; or (b) any attempt, conspiracy, incitement, instigation, command or procurement to commit an act referred to in paragraph (a).8 This restrictive definition had created a massive challenge for the South African TRC on what this definition includes or not.9Hence, this definition was amended in 1996 by adding to (b) any attempt, conspiracy, incitement, instigation, command or procurement to commit an act referred to in paragraph (a) ... within or outside the Republic, and the commission of which was carried out, advised, planned, directed, commanded or ordered, by any person acting with a political motive.10 The Zimbabwean National Peace and Reconciliation Act, which is the enabling law for the operalisation of Zimbabwe’s National Peace and Reconciliation Commission (NPRC), does not provide a definition for human rights violations; the only violation it mentions is in Section 252 (e) instructing the NPRC to develop programmes to ensure that persons subjected to persecution, torture and other forms of abuse receive rehabilitative treatment and support.11 This lack of definition might hamper the work of the NPRC as was the case with the South African TRC. There might be a need to amend the act by adding a precise definition, which type of violations the commission is mandated to deal with. 8 Promotion of National Unity and Reconciliation Act 34 of 1995; http://www.justice.gov.za/legislation/acts/1995-034.pdf 9 Nelson Mandela Centre of Memory: Chapter 1. Analysis of Gross Violations of Human Rights; https://omalley.nelsonmandela.org/omalley/index.php/site/q/03lv02167/04lv02264/05lv02335/06lv02357/07 lv02398/08lv02399.htm 10 NO. 104 OF 1996: Judicial matters amendment act, 1996; http://www.justice.gov.za/legislation/acts/1996104.pdf 11 National Peace and Reconciliation Commission Act (Chapter 10:32)¸https://zimlii.org/zw/legislation/act/2017/11 8 DRAFT