17 Introduction Commission on Human and Peoples’ Rights ruled against the Zambian government in both Kaunda’s and Banda and Chinula’s cases – but again not in time to enable them to contest for political office when they wished. The Tanzanian government, despite its mostly positive record, has also attempted to use citizenship law to denationalize several journalists and other critics. In 2001, the government declared four individuals – including Jenerali Ulimwengu, a leading pub­ lisher, journalist and media proprietor; and the country’s then high commissioner to Nigeria, Timothy Bandora – to be noncitizens. In 2006, the government again stripped two journalists of their nationality, accusing them of being ‘unpatriotic and enemies of the state’. These cases continue. In Zimbabwe, as in Côte d’Ivoire, a general programme of denationalization has had the benefit of providing scope for the government also to silence troublesome individuals (or simply to humiliate past enemies). In Dec­ember 2005, the Zimbabwean government informed Trevor Ncube, owner of two independent newspapers that were highly critical of President Mugabe’s policies, that he had forfeited his Zim­babwean citizenship because he had failed to renounce his Zambian citizenship – which he had never claimed but was ­allegedly entitled to because his father was born in Zambia. Ncube’s passport was restored to him following a court order. Others who had their passports taken away for good included the last Rhodesian prime minister, Ian Smith, and his predecessor Sir Garfield Todd, deposed as head of government when he tried to liberalize Rhodesia’s apartheidstyle rule – and then also deprived of his passport by Ian Smith’s government. Judith Todd, daughter of Garfield Todd and herself a high-profile opponent of the former white minority regime and an activist under the new government, was also deprived of her passport on the basis that she had a notional entitlement to New Zealand citizenship.