217. The two issues that had to be determined by the Court were: (i) whether the applicant’s freedom of expression guaranteed under Article 20 of the Constitution was contravened; and (ii) whether, if the answer to the first question was in the affirmative, the Court had the jurisdiction to grant the applicant the relief he was seeking. 218. The High Court held that it by Article 28 of the Constitution, it had jurisdiction to hear and determine applications made to enforce the Bill of Rights, Part III of the Constitution. The Court also held that the applicant’s freedom of expression had been infringed upon and quashed the charges against him. 219. Compensation is available to a person who was unlawfully detained and seeks damages in tort for false imprisonment. C. ADMINISTRATIVE MEASURES 220. As earlier reported the PPCA and the PLPSU deal with interlaid matters relating to abuse of authority by police officers. D. FACTORS AND DIFFICULTIES 221. Although Zambian legislation provides for bail, its conditions are not easily met by some accused persons because of financial constraints. 222. The State party recognizes that criminal court proceedings may be prolonged by non availability of witnesses on the part of both the State and defence; non availability of the accused or the magistrate; and lack of adequate court rooms especially for magistrates. 97