AND WHEREAS the following charges are laid against the President of the Republic of Zimbabwe in terms of Section 97(1)(a), (b), (c), and (d) of the Constitution of Zimbabwe.
a) Serious Misconduct
i) The President abrogated his constitutional mandate to his wife who has made utterances on issues of Government like the appointment and dismissal of Government Ministers and senior civil servants.
ii) The President totally ignored all allegations of corruption and misappropriation of public funds e.g. the case of ZESA where five million United States dollars (USD 5, 000, 000.00) was unlawfully and corruptly released to a known convicted criminal and some of the money ended up in the responsible Minister’s bank account.
iii) Allowing his wife to usurp Government functions and access classified and privileged information and the wife openly acknowledged it during numerous political rallies.
iv) Allowing his wife to abuse State resources.
v) Allowing his wife to insult and humiliate VP Mnangagwa and other Government Officials in public.
vi) Allowing his wife to threaten to kill VP Mnangagwa and Government Officials.
vii) Causing disaffection amongst the Defence Forces by allowing his wife to make reckless and false allegations against the country’s Defence Forces.
viii) Harbouring fugitives Professor Jonathan Moyo and Mr. Saviour Kasukuwere from justice.
(b) and (c) Failure to obey, uphold or defend this Constitution /willful violation of this Constitution
i) Contrary to Section 308 (2) of the Constitution he directed, caused or acquiesced with Dr. I. C. M. Chombo to write to the Zimbabwe Anti-Corruption Commission (ZAAC) justifying unconstitutional and illegal misappropriation of Zimbabwe Manpower Development Funds (ZIMDEF) by Professor Jonathan Moyo thereby defeating the course of justice.
ii) Contrary to Section 259 (7) as read together with Section 187 of the Constitution, he reversed the appointment of Prosecutor General Ray Goba to protect Professor Jonathan Moyo from prosecution.
d) Inability to perform the functions of the Office because of physical or mental incapacity.
i) Because of old age, he is unable to represent the State with decorum and dignity expected of the Office in that he has to be hand held by either his wife or an aide to avoid stumbling or falling.
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