such imprisonment” under Section 14 (2) of the Commission of Inquiries Act is also clearly draconian. f. The possibility of police involvement in investigations of the Commission under Section 10 (4) of the ZMC Bill as well as Section 18 of the Commissions of Inquiry Act could be problematic because: i. This suggests the criminalisation of communication activities, and ii. It might compromise the independence (or even the reputation) of the Commission. g. That Section 16 of the ZMC Bill entrenches a right of Appeal is positive. It would be even better to have a schedule with attendant Appeal Rules to give full effect to relevant appeal-related constitutional rights. h. Part IV of the ZMC Bill omits provisions on the establishment of a Media Fund. AIPPA carries provisions for the establishment of such a Fund, and this must be maintained in the new law. The Commission must plough some of the funds it collects back into the media sector. i. The Declaration on Principles of Freedom of Expression in Africa (adopted by the African Commission on Human and People’s Rights in 2002) is instructive in respect to the issue of self-regulation. Article 9 (3) of the Declaration refers to effective selfregulation as the best system for upholding and promoting high standards in the media. This means Zimbabwe must take every step possible, including recognition of existing self-regulatory mechanisms in the proposed ZMC Bill. j. ZMC Bill lacks clarity on the relationship between the Voluntary Media Council or any other self-regulatory mechanism with the ZMC. 9