in which it is capable of being read, viewed or heard by the requester. This position is recommended for Zimbabwe’s Freedom of Information Bill and law. Accessibility is important for the realisation of the State’s duty to ensure that people living with disabilities do not suffer any prejudice as a result of their disability. 4.2 Grounds of refusal Part IV of the Bill discusses protected information that may not be disclosed in response to an information request. The grounds for refusal of access to information recognised by this Bill are as follows: • Protection of personal information of a third party who is a natural person (Section 21) • Protection of commercial information of third party and private entity (Section 22) • Protection of certain other confidential information of third party (Section 23) • Protection of safety of individuals and property (Section 24) • Protection of information in bail proceedings, law enforcement and other legal proceedings (Section 25) • Protection of legally privileged information (Section 26) • Protection of defence, security and international relations of the State (Section 27) • Protection of economic interests and financial welfare of the State and commercial interests of public entities (Section 28) • Protection of research information of third party or public entity (Section 29) • Operations of public entities (Section 30) • Manifestly frivolous or vexatious requests, or substantial and unreasonable diversion of resources (Section 31) Section 25 of the Model Law deals with exemptions (such as the ones listed above) that form part of national ATI laws such as the Bill under consideration. The Model Law states that: Notwithstanding any of the exemptions (in the ATI law), an information holder may only refuse a requester access to information if the harm to the interest protected under the relevant exemption that would result from the release of the information, demonstrably outweighs the public interest in the release of the information. In addition to the position in the Model Law, courts have observed that the interpretation of the exclusionary grounds “must be read as narrowly as possible, consistent with their purpose of protecting specific rights or 13