of defence, security and international relations of the State18, are wide, far-reaching, and unjustifiable in an open and democratic society. Another unjustifiable exemption is that found in Section 31 that deals with manifestly frivolous or vexatious requests, or substantial and unreasonable diversion of resources. This is a broad provision that is open to abuse. The Model Law only refers to vexatious requests. In such cases, the Model Law requires an information officer to sign an affidavit stating the reasons why the information officer considers the request vexatious19. It is also worth pointing out the very low thresholds that trigger the rejection of requests for information that is listed under the grounds for refusal. For example, the Bill mostly speaks of ‘information ‘likely to cause,’ or ‘constitutes’ or ‘reasonably expected to.’ This is different from the Model Law that uses varying, but absolute references such as information that causes ‘substantial prejudice’ or ‘substantial harm to …’ The language used in the current Bill means that an information officer may easily deny a request for information based on untested and unreliable suspicions that may or may not happen. 4.3 Appeal Mechanism The Memorandum of the Bill makes mention of an internal appeals procedure. An internal appeal is understood as an appeal initiated by a requester of information and heard internally within the entity that has refused to grant access to requested information. The preliminary summary/ description of Section 38 also makes reference to internal appeal procedures, but the actual body of the Bill, including Section 38, does not mention any internal appeal procedures. Instead, Sections 35 and 38 imply that appeals are directed to the Zimbabwe Media Commission. It is not clear whether the Bill’s silence on internal appeal procedures is intentional or is the result of an omission or a drafting error. The preliminary part of the Bill refers to the ability to appeal against decisions made by the Commission at the High Court. According to Section 38 (5) (b) of the Bill, when refusing to grant access to information, the Commission must give notice which informs the applicant or the third party that they may appeal to the High Court against the (Commission’s) decision on appeal within 30 days of the date of the decision and the procedure for lodging the appeal. There is no further information in the Bill about whether appeals to the High Court are of a civil or criminal nature. There is no additional information about what powers the High Court will have when handling such appeals. It is recommended that the issues relating to internal appeals and the involvement of the High Court 18 19 Section 27 of the Bill Section 37(2) of the Model Law 15