While police have been quick to make these kinds of arrests based on politically motivated charges, no action has been taken against those who attack MDC members and supporters. On May 8, in connection with the case of Muchadehama cited above, police arrested High Court Clerk Constance Gambara and charged her with abuse of office for allegedly improperly facilitating the release of two MDC officials and a journalist on bail. The 26-yearold clerk was jailed, with the consequence that she had to take her nine-month-old baby to jail with her.39 Although Gambara was granted bail, the prosecutor invoked article 121 of the Criminal Procedure and Evidence Act (CPEA), resulting in Gambara’s remaining in remand prison with her baby for a week before eventually being released. An assistant master of High Court, Caroline Mafuka, was also arrested in connection with the same case.40 At the time of writing the case had not yet been finalized in court. Targeting of Commercial Farmers Human Rights Watch has documented scores of illegal attacks on commercial farms since the power-sharing government took office. The vast majority of farm invasions were led by people with close links to ZANU-PF or by those holding senior positions within the party or government. They have used violence and threats of violence to forcibly evict sitting owners from their properties.41 The invasions typically disregarded due process of law, which stipulates that the only lawful method of removing a sitting occupier from his land is by a valid eviction order from the courts. In addition, any such order must be enforced by someone with the properly designated legal authority, usually a deputy sheriff or a messenger of court.42 The power-sharing government acknowledged the problem of farm invasions and announced a ministerial fact-finding team, led by Deputy Prime Minister Arthur Mutambara, to 38 “Magistrate acquitted at close of State’s case,” Zimbabwe Lawyers for Human Rights press statement, August 4, 2009, emailed to Human Rights Watch. 39 Jan Raath, “Constance Gambara held over bail for Zimbabwe opposition MDC,” Times (UK), May 15, 2009, http://www.timesonline.co.uk/tol/news/world/africa/article6289709.ece (accessed June 22, 2009). 40 Ibid. See also Raymond Mhaka, “Court Official Arrested after Release of Mudzingwa,” Zimbabwe Metro, May 8, 2009, http://www.zimbabwemetro.com/news/court-official-arrested-after-release-of-gandhi-mudzingwa/ (accessed August 12, 2009). 41 Zimbabwe Human Rights NGO Forum, Political Violence Report, April 2009. 42 Peace Watch, Veritas, June 10, 2009, emailed to Human Rights Watch. 11 Human Rights Watch | August 2009