and utilization of resources and means to ensure their livelihood, including food security. Finally, whenever an individual or group is unable, for reasons beyond their control, to enjoy the right to adequate food by the means at their disposal, States have the obligation to fulfill (provide) that right directly. This obligation also applies for persons who are victims of natural or other disasters.56 General Comment 12 stresses the need for accountability and transparency in implementing national strategies for the right to food: The formulation and implementation of national strategies for the right to food requires full compliance with the principles of accountability, transparency, people’s participation … Appropriate institutional mechanisms should be devised to secure a representative process towards the formulation of a strategy, drawing on all available domestic expertise relevant to food and nutrition.57 It is not sufficient for the government to assert that it will provide food should food shortages materialize. Rather, the government has an obligation to justify and support its capacity to do so. While the government continues to obscure the GMB’s operations, the sources of GMB grain, and the size of the government’s strategic maize reserve, it is difficult for Zimbabweans, let alone the international community, to plan appropriately for the future and to ensure access to sufficient quantities of food. To the extent that the government’s strategy involves a decentralized approach, the national government remains accountable under the Covenant for the actions of its agents who are implementing that strategy.58 Such accountability includes responsibility for any arbitrary or discriminatory actions that deprive those in need of access to food, whether by village heads, other local community leaders, or ZANU PF supporters.59 56 ‘The right to adequate food (Art. 11),’ May 12, 1999. E/C.12/1999/5, CESCR General Comment 12 (15). (General Comments). 57 ‘The right to adequate food (Art. 11),’ May 12, 1999. E/C.12/1999/5, CESCR General Comment 12 (23) and (24). (General Comments). 58 ‘The right to adequate food (Art. 11),’ May 12, 1999. E/C.12/1999/5, CESCR General Comment 12 (20). (General Comments). 59 ‘The right to adequate food (Art. 11),’ May 12, 1999. E/C.12/1999/5, CESCR General Comment 19. (General Comments). “Violations of the right to food can occur through the direct action of States or other entities insufficiently regulated by States. These include … denial of access to food to particular individuals or groups, whether the discrimination is based on legislation or is pro-active; the prevention of access to humanitarian food aid in internal conflicts or other emergency situations; … and failure to regulate activities of individuals or groups so as to prevent them from violating the right of food of others ….” 14