Case Three: Affidavit of Gabriel Shumba I, Gabriel Shumba, born on 10 November 1973: National Identity Number: 12-046647F12, Passport number: ZE130844 and of Centre for Human Rights, University of Pretoria, Pretoria 0002, South Africa, do hereby solemnly swear as follows: 1. I am a citizen of Zimbabwe. I am also a holder of a Master’s Degree in Human Rights Law, and a Human Rights Lawyer, duly sworn and practising as such in Zimbabwe. 2. Pursuant to the call of my profession, on the 14th of January 2003 I consented to represent one Job Sikhala, the opposition Member of Parliament for Saint Mary’s. He had engaged me to represent him in a matter in which he alleged political harassment by members of the Zimbabwe Republic Police (ZRP). At that moment in time, Job Sikhala was hiding from the police. 3. My young brother, Bishop Shumba accompanied me to the Saint Mary’s Hotel where Mr Sikhala was booked. I found Mr Sikhala in the company of one Taurai Magaya and Charles Mutama. I then proceeded to take instructions and confer with Mr Sikhala. However, at or about 23:00 hrs on the said day, riot police accompanied by plain-clothes policemen and personnel who I later discovered were from the Central Intelligence Organisation (CIO), the spy agency of the government, stormed the room. 4. I identified myself as a lawyer and enquired as to the nature and purpose of the police actions. Thereupon, one of the officers confiscated my lawyers practising certificate and informed me that there was no place for human rights lawyers in Zimbabwe. Others grabbed my diary as well as files and documents. All of us were prodded with guns in the back and bundled into a police defender vehicle. Several acts of assault and violence were perpetrated upon my person. In particular, I was slapped several times and kicked with booted-feet by amongst others, a certain detective inspector Mbedzi, the officer in charge of Saint Mary’s Police Station. 5. Moments later, we were driven to Saint Mary’s Police Station but no charges were preferred. We were denied access to legal representation and were abused and insulted for allegedly working cahoots with ‘western powers’ in an attempt to reverse the gains of the liberation struggle. Our cell phones were also confiscated, and we were denied contact with our lawyers, relatives and friends. 6. Around 01:00 am, we were driven to Matapi Police Station where Mr Sikhala and Bishop were booked into the holding cells. I was taken to Mbare Police Holding Cells, whilst, as I subsequently discovered, Mr Magaya and Mr Mutama were deposited at Harare Central Police Station. 7. I was only booked into the cells at around 03:00 am. I was denied blankets and had to sleep on a concrete floor. The cell that was about 3m X 4m housed over 20 inmates. I had to spend the whole night squatting in a pool of urine and human waste. All night long, I had to endure the torment of lice and bed-bugs bites. 8. My constant pleas for legal representation, food and water were in vain. Around 12:00 pm on the next day, personnel from the CID (law and order section) of the Harare Central Police Station booked me out of Mbare. Again at this juncture, I had not been informed of the nature of the charges preferred against me. The police were under the charge-ship of one Detective Inspector Garnet Sikhova. I was taken to a yellow mini-bus whose registration numbers I was 86