The governing framework on hunting in Zimbabwe consists mainly of the Parks and Wildlife Act and the Parks and Wildlife (General) Regulations. The definition of hunting in the Act is: “(a) to kill, injure, shoot at or capture; or (b) with intent to kill, injure, shoot at or capture, to wilfully disturb or molest by any method; or (c) with intent to kill, injure, shoot at or capture, to lie in wait for, follow or search for”. The Act does not define fishing. While this definition does not provide a classification of hunting, various sections of the Act identify some types of hunting. The Act establishes four ‘appropriate authorities’(AAs) that are authorized to hunt within their respective areas of control. The Parks and Wildlife Management Authority is the AA for the parks area, which includes any botanical garden, botanical reserve, national park, recreational park, safari area or sanctuary. The Forestry Commission is the AA for forest land. The owner of privately owned land is the AA. The Rural District Councils (RDCs) are the AAs for Communal Land. A Cabinet decision was announced in September 2020 to devolve the AA to sub-district levels, but there is no legal provision devolving AA to sub district levels. As a result, the Community Conservancies in Zimbabwe are formed as Environment Sub-committees in terms of Section 61 part (6) of the RDC Act and Section 133 of the Environment Management Act and are therefore RDC structures and not community structures. The AA for fishing waters can be any person appointed by the Minister or the AA for the riparian land of such waters.

The Parks and Wildlife Act recognizes the power of the AAs to issue, amend, or revoke hunting or fishing permits. The AA sets out the terms and conditions of the permits.

The Parks and Wildlife Act and Regulations contain rules and forms for obtaining permits to conduct various wildlife-related activities. Hunting of any wildlife or fishing requires a permit issued by the ‘appropriate authorities’ (AAs). The Parks and Wildlife Act does not provide a definition of a permit. However, it recognizes several types of permits for hunting depending either on the type of animal hunted, or the area where the hunt is being conducted. Hunting within the national parks is strictly prohibited, while hunting within sanctuaries and safari areas requires permits issued by the Parks and Wildlife Management Authority with the concurrence of the Minister. Hunting of specially protected animals on any land other than a national park is allowed with a permit issued by the Parks and Wildlife Management Authority with the concurrence of the Minister. With regards to hunting in any land excluding national parks, sanctuaries and safari areas, the Parks and Wildlife Act grants the AA of that land the power to hunt any animal on the land, or issue a permit to any person allowing him/her or any other person or any class of persons to hunt any animal on the land. Regarding fishing, the Act provides that the AA for any waters may fish at any time in the waters or issue a permit to any person allowing him/her or any other person or any class of persons to fish in the waters.

The Parks and Wildlife Regulations recognizes three categories of permits that are not transferable: the fishing permit, the hunting permit and the general permit. The Regulations do not define the scope of the general permit, but a hunting or fishing permit grants the holder the rights to fish or hunt and sets out the conditions therein. Within the hunting permit category, there are specific licences applicable to safari hunting in safari areas: the professional hunter’s licence, the learner professional hunter's licence, and the professional guide's licence.  The permits are issued by the AA of the land or waterbody in which such hunting or fishing is being conducted. It is the AA that sets out the conditions of validity of the permit, which includes the validity period of the permit. The validity period of the professional hunter’s licence, the learner professional hunter's licence and the professional guide's licence, which are provided for in the Regulations, expires on 31 December of the year of issue.

The Parks and Wildlife Management Authority (Tariff of Fees) By-laws, 2019 identify two broad types of permits: the hunting and fishing permits. These two categories are further categorized according to usage:
a) Under fishing permits, the By-laws differentiate between an ordinary permit and a commercial permit for cray fishing. They further identify subsistence fishing by resident communities who need subsistence fishing permit granted by the station manager responsible for the waterbody and that does not require any written formality, and commercial fishing that requires a written commercial fishing permit.

b) Under the hunting permit category, they differentiate between ordinary hunting permit and a special hunting permit for dangerous game, a special hunting permit for plain game, a special permit for bow-hunting, and a special permit for using dogs as well as a special permit for backpacker hunting.  While local communities have been conferred the use and custody rights of wildlife, the law does not recognize subsistence hunting.

The Parks and Wildlife Act does not provide a definition of subsistence hunting or fishing. As a result, the Act does not make any provision for subsistence hunting, but the By-laws recognize subsistence fishing by local fishing communities who are required fishing permits.

The By-laws set out the fees for each specific form of permit. For instance, in 2019, the costs of permits for cray fishing were US$5 per day for three nets for the ordinary permit and US$100.00 for 50 cages per month for the commercial permit. Subsistence fishing permits by resident communities are charged US$1.00 for a maximum volume of fish to be determined by the station responsible for the waterbody for rod and line fishing. The minimum annual permit fees for commercial/gillnet fishing at Chivero dam are US$3 500.00, and US$50.00 at private dams. The professional guide’s licence costs US$100.00 per annum; the professional hunter’s licence, $200.00 per annum; the learner’s hunter licence, US$50.00 per annum; and a hunting permit, US$50.00 per annum ; special hunting permits for dangerous game, including the use of bows, arrows and handguns, cost $1 500.00; special hunting permits for plain game, including the use for bows, arrows and handguns, $100.00; US$1 500.00, per pack of 12 dogs, or special hunting permit, using dogs; and US$300.00, for backpacker hunting.

Hunting without a permit is a criminal offence punishable by a level 6 fine and/or one-year imprisonment. Fishing without a permit is also a criminal offence punishable by a level 5 fine and/or six months imprisonment.

The governing framework on the identification of species consists mainly of the Parks and Wildlife Act and Regulations. The Parks and Wildlife Act establishes four broad categories of species: the specially protected animals listed in Schedule Six of the Act; the problem animals listed in the Eighth Schedule; dangerous animals listed in the Ninth Schedule; and other animals that do not fall within the above-specified categories. The procedure for listing or delisting animals from the above lists is centralized and non-consultative. The Minister has only to consult and act from the recommendations of the Parks and Wildlife Management Authority; no other stakeholders are included in the process. Further, neither the Act nor the Regulations provide a list of animals for a specific type of hunting. However, bow-hunting Class A Game (elephant, buffalo and hippo) is not permitted in Zimbabwe unless a special bow-hunting permit for these species has been granted by the Director General of the Parks and Wildlife Management Authority. The Act identifies some species of animals as specially protected. The animals specified in the Sixth Schedule are declared to be specially protected animals. The list is divided into mammals, reptiles, and birds. The Minister may, on the recommendation of, or after consultation with, the Parks and Wildlife Management Authority, by notice in a statutory instrument, amend the Sixth Schedule by adding or removing the name of any animal. The hunting, possession and trade in specially protected animals or their trophy is strictly regulated by the Act. The hunting of a specially protected animal in a national park is prohibited; the only exception is when a hunting permit is issued to hunt an injured or sick animal, or an animal causing damage to property or considered a danger to humans. Strict hunting restrictions also apply to areas falling outside national parks such as sanctuaries and safari areas. According to the Act, a permit to hunt a specially protected animal in any land, including privately owned land, may only be granted by the Parks and Wildlife Management Authority with the concurrence of the Minister. Further, the Authority shall not grant a permit unless it is satisfied that the hunting or taking is necessary for scientific or educational purposes, or for providing specimens for a museum, zoological garden or similar institution, or for the purpose of falconry, captive breeding, export or restocking, or for the management and control of animal populations, the protection of human life or property, or any other purpose that, in the opinion of the Authority, is in the interests of the conservation of animals.

The hunting of a specially protected animal in contravention of the Act is a criminal offence punishable by sanctions ranging from three to twenty years imprisonment.

There are basically two types of quota setting in Zimbabwe: the national adaptive determination of quotas and the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) quota. The first is undertaken by the Parks and Wildlife Management Authority, which is entrusted with the task of managing the entire wildlife population of Zimbabwe. The Authority permits controlled hunting through a comprehensive quota system that allows for sustainable and non-destructive hunting. However, the Parks and Wildlife Act and Regulations do not make provision for a clear procedure for quota setting. As such, there are no standard guidelines on how the quotas are set, and the consultation and participation procedure are not set out in the Act or Regulations. While the Act does not make provision for an adaptive determination of quotas to safari hunting, in practice, the Parks and Wildlife Management Authority conducts national workshops of key stakeholders to determine annual quotas. Each year, the AAs that include private landowners, Rural District Councils (RDCs) and the Forestry Commission apply to the Authority for annual hunting quotas. In setting up quotas, the participatory method is used whereby all stakeholders gather and deliberate on hunting quotas (using best available information), which include population data, trophy quality data, consideration of habitat and land tenure factors, and consideration of a range of additional inputs. The Authority seeks to rely on inputs from monitoring data and input from a variety of stakeholders, including the Authority’s field and research staff, local communities, hunting operators, and non-government biologists or researchers. The aim of these workshops is to produce adaptive and sustainable offtakes that benefit both the wildlife resource and the stakeholders. However, the quota-setting procedure is hindered because the Act does not contain express provisions on monitoring and quota system. Although the Act and Regulations require that each permit holder record animals seen, their sex and number of animals hunted, the hunter has no obligation to transmit the data to the Authority (with the exception of safari hunting).

With regard to trade, the Wildlife (Import and Export) Regulations domesticate the CITES. CITES is the principal international instrument that regulates quota setting of the hunting and trade in endangered species. Zimbabwe’s legislation is in Category 1 of CITES, that means, it meets the main requirements defined by the Secretariat for CITES implementation. The Parks and Wildlife Management Authority applies to CITES each year for quotas of endangered species such as the elephant, leopard, cheetah and crocodile. Species listed under CITES Appendix I are those for which international trade for non-commercial purposes is permitted but strictly controlled by a permit system. The Conference of the Parties (CoP) may also establish export quotas for non-commercial trade that are recognized as not detrimental to the species by Resolution or Decision. Zimbabwe utilizes this procedure to apply to CITES for quotas. It should be noted, however, that Zimbabwe’s CITES export quota is not the same as the national hunting quotas.

For fishing, the Parks and Wildlife Regulations provide that the person issuing the fishing permit may limit the number and species of fish which may be taken. The Parks and Wildlife Management Authority (Tariff of Fees) By-laws, 2019 limit the number of fish allowed per day for leisure fishing to five and mandate the local station responsible for the waterbody to determine the maximum volume of fish that may be taken for subsistence fishing.

There are no defined hunting seasons in terms of the Parks and Wildlife Act and its Regulations in Zimbabwe. Although the Act does not specify hunting or fishing seasons, the ‘appropriate authority’ (AA) has the power to set out hunting seasons within its boundaries. In terms of the Act, the AA has the power to issue or refuse to issue permits and it has the power to impose any terms and conditions it deems appropriate. The AA may utilize this provision to define hunting or fishing seasons within its land or waterbody. The Minister of Environment can also, by a notice in a statutory instrument, specify periods during which specific species may not be hunted in the area of an environment committee.

Further, there is no regulation controlling the number of days of hunting safaris. The AA is responsible for setting the number of days as part of the terms and conditions of the permits. The Regulations, however, prohibit night-time hunting within the Parks and Wildlife Estate. The Parks and Wildlife Estate includes national parks, sanctuaries, botanical reserves, safari areas and recreational parks that fall under the Parks and Wildlife Management Authority. This prohibition seems only to apply within the Parks and Wildlife Estate. In Communal Lands and privately owned lands, night-time hunting is allowed.

Any person acting in violation of the hunting permit becomes liable to a fine not exceeding level 6, and/or to imprisonment for a period not exceeding one year, including for not respecting the hunting/fishing seasons indicated in the permit. The same level of sanction applies for a person acting in violation of the hunting season specified by the Minister by notice in a statutory instrument. 

The Trapping of Animals Act prohibits the use of Class I traps in hunting and restricts the use of Class II and III traps. Although the Parks and Wildlife Act sets out clear and structured restrictions on the harvesting methods and tools used for fishing, it does not set out harvesting methods and tools for hunting. These are, rather, provided for under the Parks and Wildlife General Regulations. The Regulations, however, only regulate hunting methods and tools within the Parks and Wildlife Estate. The harvesting methods and tools set out in the Regulations therefore do not apply to hunting within forest land, communal land or private land where potentially no tool restrictions apply. Regarding fishing, section 87 of the Act prohibits the use of explosives, firearms, chemicals, jigs, electrical devices and fishing nets without a permit. Killing any fish with explosive charge, the discharge of a firearm, or the introduction into the waters of any chemical, poison or intoxicating substance; or fishing by jigging or by means of any jig or an electrical device; or wilfully injuring or disturbing the spawn of any fish or any spawning bed, bank or shallow whereon or wherein such spawn is deposited is a criminal offence under the Act and is punishable by a fine not exceeding level 6 and/or one year in prison. The Act identifies acceptable fishing methods, which include using a rod and a line, spears, spear guns and basket traps.

The Parks and Wildlife Regulations prohibit the following hunting methods and tools within the Parks and Wildlife Estate: sound equipment, fire, aircraft, dazzling light, shooting of animals within 400 m of a prescribed road or development area, or watering hole; use of a pistol, crossbow, bow and arrow, rifle or shotgun capable of firing more than one cartridge per trigger; a weapon with the length of barrel less than 500 mm; and shooting animals while in a vehicle, vessel or aircraft. The Regulations provide that within 12 hours after the hunt or sighting of an animal, the holder of a hunting or general permit must generate a record of the particulars of the animal seen or hunted and submit it to an officer within a specified period of time (at least 21 days from the expiry date of the permit). Further, at the conclusion of a safari hunt, the operator must sign a form indicating the particulars of the animal hunted and such form must be sent to the Director of the Parks and Wildlife Management Authority within 14 days.

There are no mechanisms for public consultation and participation in the listing or delisting of hunting and fishing methods. Further, the law does not regulate the game age or size limit for hunting/fishing. Also, there are no provisions for sex-based limitations on hunting. In terms of the Parks and Wildlife (General) Regulations,1990, using prohibited hunting and weapons is punishable by a fine and/or a maximum of one year in prison.

There are three main governmental agencies involved in the management and conservation of wildlife in Zimbabwe known as the ‘appropriate authorities’ (AAs) in terms of the Parks and Wildlife Act. These are the Parks and Wildlife Management Authority, established by section 3 of the Parks and Wildlife Act; the Forestry Commission, established by section 4 of the Forest Act; and the Rural District Councils (RDCs), established by section 8 of the Rural District Councils Act. In addition to these three, owners of alienated land are also vested with custodian rights as the AAs. The Parks and Wildlife Management Authority is entrusted with the task of managing the entire wildlife population of Zimbabwe, whether on private, state and communal land, which includes the management of Zimbabwe’s 11 national parks, recreational parks, safari areas and sanctuaries. Pursuant to the Forest Act, wild animals are to be considered “forest produce” if found in “demarcated forests”. The Forestry Commission owns and is in charge of managing forest produce within demarcated forests. Therefore, a direct responsibility of the Forestry Commission is to manage wildlife in the demarcated forests, which potentially overlaps with the mandate of the Parks and Wildlife Management Authority. Regarding other forest areas, the Forestry Commission is the AA in terms of the Parks and Wildlife Act. The Rural District Councils Act (Chapter 29:13) provides for the establishment of environment committees (called ‘conservation committees’ before the Environmental Management Act amended this Act) within Rural District Councils. These committees are delegated specific functions under the Parks and Wildlife Act with regard to the protection of animals in alienated land within the area of the environment committee. The Parks and Wildlife Act grants all the above institutions AA status. The RDCs are granted AA status for the management of wildlife on Communal Land on behalf of communities. The Constitution requires that all these institutions be accountable and transparent. Further, they must promote the rule of law and equality, as well as human dignity and empowerment. The conduct of these institutions must be lawful, prompt, efficient, reasonable, proportionate, impartial and both substantively and procedurally fair. The decisions and conduct of the public institutions are open to judicial review by the High Court of Zimbabwe.

Although the Parks and Wildlife Act grants ‘appropriate authority’ (AA) status to various institutions over different categories of land with power and authority to manage wildlife within their respective categories, it does not establish any mandatory coordination and procedures for coordination. Thus, although the Parks and Wildlife Management Authority remains the principal authority in the management and conservation of wildlife in Zimbabwe, the law does not set out the coordination mechanisms with other stakeholders in the wildlife management sector.

The Parks and Wildlife Act does not contain a specific provision on the delegation of powers of the Parks and Wildlife Management Authority. It is therefore not clear which powers are subject to delegation and to whom, and under what circumstances can such delegation be withdrawn. However, the Act through the establishment of AA status delegates some of its functions in the management of wildlife to Rural District Councils (RDCs), private landowners and the Forestry Commission. For instance, RDCs are conservation committees in terms of section 61 of the Rural District Councils Act (also referred to as ‘environment committees’ in the Environmental Management Act). In order to more effectively carry out its functions as a conservation committee, a council may appoint one or more natural resources conservation subcommittees to exercise functions relating to the natural resources within one or more wards of the council area; and delegate to any such natural resources conservation subcommittee all or any of its functions as a conservation committee.

There is a general prohibition in terms of the Parks and Wildlife Act to sell, possess or consume the meat of any animal or any fish that has been hunted and caught in contravention of the Act. Such conduct is an offence that carries a sentence of a fine not exceeding level 6 and/or imprisonment for a period not exceeding one year. A hunting or fishing permit is a prerequisite for any lawful hunting and fishing. The only exception to the permit requirements relates to leisure fishing. The Parks and Wildlife Management Authority (Tariff of Fees) By-laws, 2019 provides that leisure fishers shall be allowed to take away five fish per day. The Regulations do not set any tariff costs for leisure fishing. Regarding subsistence fishing for local resident communities, the Parks and Wildlife Management Authority (Tariff of Fees) By-laws, 2019 provide for a simplified permit application system. The local authorities may further regulate the consumption of wildlife meat through by-laws. For instance, the Harare City Council regulates the consumption of wild meat through the Harare (Meat) By-laws. Section 6 of the By-laws provides that no game meat shall be sold in the council area unless it has been inspected and supplied by a person registered with the council.

The Parks and Wildlife Act prohibits the sale of fish/game meat without a hunting or fishing permit. Any meat or fish for retail must have been lawfully hunted or caught in accordance with the Act. Section 90(1) of the Act provides that no person shall carry on the business of catching fish in any waters and selling it except when holding a permit issued in terms of section 94. Section 94 provides that the Parks and Wildlife Management Authority, with the concurrence of the Minister, may issue a permit to any person to carry on the business of catching fish by means of a fishing net or by other means in any waters and selling such fish. The Act, however, does not provide for a licensing system for retailers of wild meat derived from hunting. The Act does not have provisions regulating the value chain of wild meat from the licenced hunter to the consumer. The handling of the game meat from the point of the hunt to the point of sale to the consumer is largely unregulated. There are no monitoring provisions requiring retailers of game meat to keep record of the source of supply, the wild species from which the game meat is derived, or how the wild-meat is prepared, preserved, packaged, stored or conveyed. Further, while the quota system is mainly used in safari/trophy hunting, there are no quotas set for the wild meat trade. The ‘appropriate authority’ (AA) of the land or the waterbody has the ultimate discretion to set and determine quotas for wild meat trade. There are no standard national guidelines that regulate the setting of wild meat trade quotas. The local authorities also have the power to regulate the retailing of wild meat within their jurisdictions. A case in point is the Harare City Council, which has gazetted by-laws regulating the retail of wild meat in Harare. The Harare (Meat) By-laws require the registration of all wild meat retailers with the Council.

Where any person is convicted of an offence of trading in game meat or fish without a permit, in contravention with the Parks and Wildlife Act, the court may order that any animal other than a specially protected animal, or the meat or trophy of any such animal, or any fish in respect of which the offence was committed shall be forfeited to the AA for the land on which the offence was committed or the AA for the waters in which the offence was committed. Furthermore, such a person is punishable by a fine of level 6 and/or one year in prison minimum in case of the sale of wild meat and fish without a permit.

The Parks and Wildlife Management Authority is the responsible institution for the distribution of wild game meat and fish. The local authorities also have the power to regulate the retailing of wild meat within their jurisdictions.

No relevant elements identified/documented.

The Parks and Wildlife Act does not provide for delegation of powers on the distribution of wild game meat and fish in Zimbabwe.