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 he 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 “The overhanging effect of the offence of criminal defamation is to stifle and silence the free flow of information in the public domain. citizenry remaining uninformed about matters This, in turn, may result in the of public significance and the unquestioned and unchecked continuation of unconscionable malpractices.” While announcing the repeal of the offences of seditious libel, defamatory libel, obscene libel and sedition, the UK secretary of State at the Ministry of Justice, Ms. Claire Ward was quoted in the UK Press Gazette, 13" January, 2010, as having said that: “Sedition and seditious and defamatory libel are arcane offences — from a bygone era when freedom of expression wasn’t seen as the right it is today... The existence of these obsolete offences in this country had heen used by other countries as justification for the retention of similar laws which have been actively used to suppress political dissent and restrict press freedom... 44 Abolishing these offences