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A Comparative Study of Freedom of Information Laws in Botswana, South Africa and Zimbabwe

Njabulo Bruce Khumalo, Sindiso Bhebhe, Olefhile Mosweu


Access to information has been a major concern all over the world, with governments drafting legislation to address it. Information is critical especially in participatory democracies where citizens need access to information to make informed decisions and governments have to be transparent. Freedom of Information legislation (FOI) has been expected to afford citizens the right to information to participate in democratic processes in their countries. FOI legislation has been enacted in some countries under the pretext that they will make information accessible. However, over the years most information access legislation and policies have come under scrutiny, for actually hindering and restricting access to information by members of the public. This study therefore compares and contrasts access to information laws of Botswana, South Africa and Zimbabwe, with the view to find disparities, parities and how restrictive or free they are. This study reviews literature on Information Access Laws of the three countries. Document analysis is used to analyse such legislation. This study will go a long way in showing how the three countries can learn from each other’s information access laws. It also reflects on the strengths and weaknesses of these laws, showing areas which need to be improved and possibly amended. There is an abundance of research on FOI conducted by various scholars but none was a comparative study of the three aforementioned countries. 


Access to information; Botswana; South Africa; Zimbabwe; freedom of information

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