6. The Second Respondent is the ATTORNEY-GENERAL OF ZIMBABWE N.O cited herein in his capacity as the chief legal advisor to the Government of Zimbabwe and its representative in constitutional matters. His address for service is New Government Complex, Corner Fourth Street and Central Avenue, Harare. NATURE OF APPLICATION 7. This is an application for a declaratory order in the terms set out in the draft order, particularly that in terms of section 156 (a) and section 239 (a) of the Constitution of Zimbabwe and section 3 of the Electoral Act the First Respondent has an obligation to conduct an election transparently and in terms of section 3 (2) (g) and section 233 (d) of the Constitution which require the First Respondent to promote transparency in all its operations. 8. In terms of the above provisions that relate to transparency, the Applicants will seek a declaratory order that the First Respondent has a legal duty to make available for public scrutiny all its standard operating procedures, processes, policies and internal manuals which relate to the conduct of elections before the 2018 elections; the names and roles of certain personnel involved in the administration of the election; the criteria by which it assesses the 3

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