morality, children, national security and development, the family and often civilization itself. Often, the subordinate group is dehumanised and compared to animals, portrayed as sub-human or in some other way less than human38. President Mugabe has sought to dehumanise gays and lesbians referring to the community as “sub animal” and behaving “worse than dogs and pigs” 39. The Supreme Court of Canada in Vriend v Alberta40 (a case dealing with discrimination in employment on the basis of sexual orientation) noted: Perhaps the most important is the psychological harm, which may ensue from this state of affairs. Fear of discrimination will logically lead to concealment of true identity and this will be harmful to personal confidence and self esteem. Compounding that effect is the implicit message conveyed by the exclusion, that gays and lesbians, unlike other individuals, are not worthy of protection. This is clearly an example of a distinction, which demeans the individual and strengthens and perpetrates [sic] the view that gays and lesbians are less worthy of protection as individuals in Canada’s society. The potential harm to dignity and perceived worth of gay and lesbian individuals constitutes a particularly cruel for of discrimination41. The South African Constitutional Court also noted the impact of criminalisation of consensual gay acts beyond that of dignity and self esteem. Criminalisation encourages blackmail, police entrapment, violence and peripheral discrimination such as refusal of facilities, accommodation and opportunities. In the Zimbabwean context, blackmail increased markedly after the homophobic pronouncements of President Mugabe. The pronouncements encouraged extortionists to believe that their victims had even more to fear if their sexual orientation were exposed. The frequency of blackmail and the quantum of money demanded rose sharply. Well organised gangs of youths approached and befriended gays at nightspots specifically for the purpose of creating a situation which might enable them to extort money. In the late 1990s, one or two cases of blackmail came to the attention of GALZ each month, although the number has dropped in recent years to three or four cases a year. Nevertheless, this is obviously only a fraction of actual incidents of blackmail. Fear prevents the people from joining GALZ in the first place and fear and lack of an appropriate response from the police also prevents many victims from reporting the problem. When a gay activist tried to lead by example and reported a case of extortion to the police, he himself was arrested. Reports of attempted extortion to police officers has resulted in police officers attempting to displace the extortioner and to demand cash themselves.42 A former Director of Public Prosecutions has admitted that blackmail is the main effect of the criminalisation of same-sex sexual activity between consenting adults43. Widespread blackmail was a major factor influencing decriminalisation in 38 This sort of rhetoric should be familiar to all who have encountered over and systematised racism. A review of any of the texts of the apartheid era in South Africa and Nazi Germany shows a striking similarity of language in this regard. 39 The Herald, 12th August. 1995. The statement was widely reported internationally – see, for example, the Globe and Mail (Toronto) of the same date. 40 (1994) 20 CHRR D/358 41 Quoted with approval in National Coalition for Gay and Lesbian Equality and Another v Minister of Justice and Others CCT11/98 at para. 23 42 43 see Propotkin, P op. cit. at pp 35-36 and n 88 Phillips, O. Zimbabwean Law and the Production of a White Man’s Disease Social and Legal Studies Vol. 6 No 4 (1997) p. 471 at p. 484