See also Castells v. Spain, Application No, 11798/85, ECHR decision of 24 April 1992, where the court while ruling that the applicant’s right to free speech had been violated, held that: …the dominant position which the Government occupies makes it necessary for it to display restraint in resorting to criminal proceedings, particularly where other means are available for replying to the unjustified attacks and criticisms of its adversaries or the media. In Sullivans case (supra) Brennan, J. went on to hold that: “A rule compelling the critic of official conduct to guarantee the truth of all his factual assertions – and to do so on pain of libel judgments virtually unlimited in amount – leads to a comparable “self-censorship.” Allowance of the defense of truth, with the burden of proving it on the defendant, does not mean that only false speech will be deterred. Even courts accepting this defense as an adequate safeguard have recognized the difficulties of adducing legal proofs that the alleged libel was true in all its factual particulars … under such a rule would-be critics of official conduct may be deterred from voicing their criticism, even though it is believed to be true and even though it is, in fact, true, because of doubt whether it can be proved in court or fear of the expense of having to do so. They tend to make only statements which “steer far wider of the unlawful zone.” The Constitutional Court of Zimbabwe in Nevanji Madanhire and Nquaba Matzhizi v Attorney General 2015 ZWCC 02, Patel, J. observed that 40