There was no satisfactory resolution of a single one of 37 petitions brought as a result of the 2000 Parliamentary Election before the next parliamentary election in 2005. None of the petitions were finalized, and, of those judgements that did take place (but against which appeals were lodged), these generally favoured the view that there had been such undue influence and violence in the constituency concerned that the outcome could not be trusted as reflecting the will of the constituents. The petition on the Presidential Election is still to be finalized, more than five years after the event. In a context where evidence suggests that judicial independence has been compromised, it is difficult to ascribe an innocent explanation for this situation. 5.5 Conclusion This brief assessment could be massively expanded by the insertion of all the supporting evidence, but it should be clear that there are no good grounds for suggesting that the Government of Zimbabwe came even close to addressing the concerns of the Commonwealth before President Robert Mugabe unilaterally withdrew Zimbabwe from the Commonwealth, and has continued to ignore these concerns subsequently. The evidence rather supports a view that the Government of Zimbabwe has been contemptuous of the rulings of the Commonwealth, and has made no or little attempt to actively engage the Commonwealth or its Secretariat. 6. What is to be done? In the history of the Commonwealth, its position on Apartheid South Africa stands as testimony to its commitment to democracy, human rights and the rule of law. The promulgation of the Harare Declaration, and Commonwealth Action Programme is in keeping with this tradition. It would be an unfortunate departure from this tradition if the Commonwealth were now to waver and not follow through with the implementation of the Harare Declaration, and procedures provided for in the event of a member’s withdrawal. Notwithstanding that the Government of Zimbabwe is unlikely to respond positively to any Commonwealth initiative whilst President Mugabe remains in power, it remains important for the Commonwealth to adopt measures on Zimbabwe in furtherance of the Commonwealth Action Programme’s call “to reinforce the need for change in the event that the government concerned chooses to leave the Commonwealth and/or persists in violating the principles of the Harare Commonwealth Declaration even after two years”. Informed by the Commonwealth Action Programme’s reference to such measures as ‘limitation of government-to-government contacts; people-to-people measures’, and by the institutions, programmes and activities of the Commonwealth, a multi-level set of actions can be undertaken to re-engage with Zimbabwe for the principal purpose of easing its return to 18