writing, the result of the inquiry within a period of three months from the date of swearing in of the Commissioners. The Presidium concern for the post-election violence was noted. Nevertheless, there is a feeling that it was not necessary to invest Zimbabwe's scarce resources into a new commission dominated by foreigners. Zimbabwe already has constitutional commissions with relatively better understanding and appreciation of the context that could have performed the same task. The terms of reference of the Commission of Inquiry to Inquire into the Post Election Violence that took place on 1 August 2018 in Zimbabwe resonate well with the functions and responsibilities of at least two independent commissions established under Chapter 12 of the Constitution of Zimbabwe Amendment (No. 20) Act 2013 namely Zimbabwe Human Rights Commission and the National Peace and Reconciliation Commission. The use of the local commissions could have made a double impact: investigative, redressing and closure. Zimbabwe's Chapter 12 Commissions report to parliament which enhances their transparency and independence. The Commission of Inquiry to Inquire into the Post Election Violence that took place on 1 August 2018 in Zimbabwe is accountable to an individual - the President. This might compromise their independence and objectivity. 6.2.3 The 2018 Harmonized Election Petition for Presidential Results History repeats itself. In 2013, then the late Chief Justice Chidyausiku made a decision pertaining to the late Morgan Tsvangirai's election petition. In that case, then Chief Justice Chidyausiku ruled that technicalities would not ordinarily interfere in dealing with such cases on the basis of their merits in court. It is facts and evidence of the case that matters. In Chamisa's election petition of 2018, the case was hinged on direct and primary source evidence. The direct and primary source evidence were the V11 and V23 returns and the results announced by the Zimbabwe Electoral Commission. Focus was therefore on the V11 and V23 forms. Discrepancies therefore were to be established on these forms. These two forms created a scientific forensic basis for establishing a clear connection between specific figures or tallies derived from the voters' roll, the total number of people who voted on different polling stations on the day through to the constituencies and finally each candidate's totals as announced by ZEC. Taking this route of the argument would lead to a game of figures which would not be disputed. On the 24th of August 2018, Chief Justice Malaba dismissed Chamisa's case with costs. The main reason for dismissing the application was a lack of evidence to support specific, particular examples of the allegations put before the court. In his words, Chief Justice Malaba, ―the courts finds that the applicant has failed to place before it clear, sufficient, direct and credible evidence that the irregularities that he alleges marred the election process materially existed. The applicant did not prove the alleged irregularities as matter of fact.ǁ it should be clear that the applicant failed to prove his case. It was failure to prove one's case hence dismissal of the case. 6.2.4 Cases of Post 2018 Harmonized Election Scenarios Case 18 A traditional leader from Takawira Resettlement in Chirumanzu District threatened all those he thought had voted for opposition political parties in 2018 Harmonized Elections. He warned them that ―ndaendesa mazita enyu mese vanhu veMDC kumusoro… muchaona vamuchaitwa - I have written down all the names of those who I know voted for MDC and I have submitted them to ZANU PF headquarters for actioningǁ. Case 19 In Muzarabani South, Ward 20 Chawarura, the bedroom of a Chairperson of an opposition political party, Stewart Kanyoka was burnt at around 3am on 10 September 2018 by one Vakira a district member of another political party. Maize, fertilizers and clothes were destroyed in the inferno. The members of the Zimbabwe Republic Police (ZRP) attended the scene after a report was made. They 44