26 S.C. 128\02 nine members. The Broadcasting Act (United Kingdom) similarly constitutes a body corporate called Independent Television composed of not less than eight and not more than ten members. In both Acts there are limitations in terms of criteria of who is to be appointed to the regulating Authority. In terms of section 6 of the Act the Minister is the licensing authority. The Board shortlists, and by public inquiry, determines or otherwise, the applicants and makes recommendations to the Minister to issue or not to issue a licence to an applicant. See section 10(9). It would appear that sections 4 and 6 of the Zimbabwean Act are modelled on sections 3 and 5 of the British Broadcasting Act. In terms of British provisions once appointed the ITC is the licensing authority. There is no involvement of the Secretary of State in regard to the granting or otherwise of licences except in circumstances set out in section 17(5) as read with subsection 6 quoted above. Thus the most significant difference between the Zimbabwean and United Kingdom legislation in this regard is that under the Zimbabwean Act the Minister continues to have decision-making powers over the authority subsequent to its appointment while the United Kingdom Act confers decision-making powers to the Commission independent from the Secretary of State subsequent to its appointment except for the special circumstances set out in section 17(5) as read with subsection 6 of the United Kingdom Act. AUSTRALIA