they make very general averments and do not themselves allege disenfranchisement by the Electoral Commission. 53.2. Secondly, his assumption that members of the civil service are opposition supporters/voters is made without foundation. Voting is by secret ballot in our electoral system, how the applicant presumes to know the voting choices of the unidentified civil servants he refers to is unclear. It cannot form the basis for the relief he seeks. 54. Ad Para 6.5.9 This is denied. 54.1. The affidavits of Mr. Jokoniah Mawopa and Mr. Obert Masaraure are presented by the applicant as showing the “actual numbers’’ of state employees allegedly disenfranchised by the Electoral Commission’s actions, those affidavits, give no actual figures as claimed by the applicant. What the deponents thereof do is to talk of an assessment process, the details or specific methodology of which they either do not share or describe in extremely sparse detail as be of no assistance in assessing the veracity of their claims. 54.2. The basis of their conclusions being unknown, such conclusions cannot be relied upon as evidence before this Honourable Court. Of the alleged 40 000 disenfranchised teachers for instance, not one has deposed to an affidavit

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