Rakgoadi, P. (1995). Community Policing in Gauteng: Policy issues. Research report written for the Centre for the Study of Violence and Reconciliation, November.
Pakiso Sylvester Rakgoadi
Research report written for the Centre for the Study of Violence and Reconciliation, November 1995.
Pakiso Sylvester Ragoadi is a former Researcher at the Centre for the Study of Violence and Reconciliation.
The process of introducing community policing philosophy in Gauteng has been an exiting one. The important facet of this process was the establishment of community police forums at police stations through out the province.1 This document draws on the draft report with a view to formulating policies which will further enhance the process which has already been initiated or any other similar or related processes which could be set up in the province. The report on Community Policing in Gauteng has brought to bear a wide range of policy issues.
This document focuses on policy issues emanating from the facilitation process. It includes recommendations from the workshop process. This process captured both the problems raised during workshops between the police and the community and suggested solutions to these problems. Some of the recommendations have far reaching implications for policing in general and for the policing of those communities in particular.
The second part focuses on policy issues which emanated from the research process. These include recommendations from the interviews with members of the police at the various police stations. An evaluation of the recommendations provided by the police is conducted with the view to assess the significance and relevance of these recommendations to the broader transformation process within the police services and their implementability.
It is important to state at the outset that the two sections are not mutually exclusive, but interdependent and interrelated. They are separated for the purposes of analytical clarity. However, this document will highlight areas of commonality and difference in these sections.
Cooperation between the Community and the Police
One of the major concerns expressed in the draft report was the lack of co-operation between the community and the police. Out is this concern arises the need to seek ways of intensifying the level of interaction between the police and the community. The lack of cooperation is a result of a long and painful history of repression, mistrust and hostility. To undo this history, the police need to develop a humane and friendly approach when interacting with members of the community or the general public by adopting a people-oriented and problem-solving approach rather than a confrontational and militaristic one.2 Such a paradigm shift will serve to cleanse the already tainted image of the police, especially in areas where there is still some degree of mistrust and hostility towards the police.
The police also need to explain police procedures and the process of investigation to the community so that members of the community can have a better understating of how the police function. An improvement in dialogue between the police and the community will enable the community to begin to appreciate the limitations and difficulties that the police encounter in executing their tasks. Effective dialogue, cooperation and collaboration will further ensure that the police become accessible to the community and the result will most likely be greater participation and cooperation of the community with the police. The police and the community could, through the community police forums, embark on a variety of projects and programmes.
Education and problem-solving workshops
These workshops could serve to address the problems that are encountered by both the police and the community. They could also be used as educational forums where the CPF, for example, explains the operational responsibility of the police and make the distinction between role and function of the CPF and that of the police so that members of the community can know what to expect from the CPF and the police in terms of the service they provide or ought to provide, namely safety and security in the case of the police. These workshops could assist in familiarising the police and community with the criminal justice system; the provisions of the Police Act; Criminal Procedure Act as amended; the Constitution, especially chapter three on the Bill of Rights and section 221 on CPFs; and the community policing philosophy.3 Such workshops could also address tensions which often arise due to some CPF members assuming the duties of the police and even interfering with police work. Moreover, the powers and functions of the CPF could be clearly specified through these workshops.4
Joint police community sports and cultural activities
The police and the community have, in many areas, perceived each other almost exclusively in the roles they played historically. The police are often not seen as citizens even when they are off duty. This relationship has resulted in the "us" and "them" syndrome which has had adverse consequences on the way they see each other. The community and the police, in some areas, continue to organise separate social activities.5 Joint social activities will help transform the perception that the community and the police relate only when there are problems. By participating in joint social and cultural activities, both the police and the community will improve communication and develop trust and confidence in one another.
Joint publication of local newsletters
These publications will report the successes and challenges facing CPFs, the community and the police. The provision of information on crime-ridden areas serves as a means to prevent crime because the potential victim would become aware of the problematic and dangerous places that they need to avoid. Again, such information could also alert the police to sites which they might not otherwise have learnt about or not being aware of. The newsletter enables ordinary members of the community to learn and know about the activities of the police and the CPF. Community members could use this medium as a means of raising their concerns in the area and thus assist the CPF in prioritising policing matters and problematic areas. The newsletter could provide information to the broader community on the activities that the police and the CPF are planning so as to invoke greater participation in the policing of their area.6
Joint anti-crime marches and patrols
The police acknowledge that they cannot confront crime alone. In situations where the policing of areas is both risky and inaccessible as is often the case in informal settlements and some townships, the police and the community can conduct joint patrols of the area or problematic and volatile sections of the area. This should not be perceived as advocating for the community to do police work. The police remain responsible for police work such as investigations. The community could in such cases participate in civilian arrests and therefore hand over suspects and criminals to the police for further investigation and prosecution by the courts.7
Lay visitor schemes
The lay visitor scheme could serve several functions which include visits to the police barracks, where they exist, to observe and evaluate the conditions in which the police live; visits to the police cells to observe and evaluate the conditions in which suspects and criminals live; and visits to police stations to observe the conditions of the police station with the view to making recommendations on the changes that need to happen. Such changes could include the renovation of police stations (see below).
Renovation of police stations
The community's perceptions of what the police station represents need to change. The repainting of some police stations could serve to improve the image of the police stations. This should not be seen as a public relations exercise, but as an essential component of how the community and the police perceive police stations and the meaning they attach to them. The police stations need to become people friendly and secure environment for community members and should no longer be seen as institutions representing repression and oppression.
Visits to police stations8
A large proportion of community members interact with the police, at police stations, only when they report cases or lay complaints. This The youth often come to police stations when they have been arrested. This relationship with the police station should begin to change because there is a lot that the youth can learn from spending time at police stations.9 They could, for instance, become familiar with policing, police structures and become police reservists and thus contribute positively to the delivery of an effective and efficient police service by protecting their communities and ensuring their safety. The education of the youth in police procedures and the structure of the police services could form part of the school curriculum.
Some CPFs are in their embryonic stage and if the relationship and co-operation between the police and the community is not harnessed and maintained, these forums are bound to collapse, degenerate into anti-crime forums or lose their credibility as instruments for changing the police institution. The process of re-establishing these forums will not only be expensive, but tedious and difficult to get off the ground.
Inclusive and Truly Representative Forums
The most common problem encountered by many CPFs throughout the country is lack of inclusive and representative forums. Lack of representivity in many forums continues unabated despite efforts to resolve this sensitive and thorny issue.10 The main cause of the problem is lack of understanding of what the CPFs are about. To some constituencies these forums are a platform for asserting power and domination in a particular area. Tensions and polarisation in most areas, especially historically black areas, has exacerbated the problem. However, this problem also exists in areas where the police initiated these forums and wanted to retain control over them. Representivity is in most cases shaped by the local dynamics. Forums viewed representivity differently and thus had different kinds of representation.11 However, for the CPFs to achieve true representivity, all affected and interested stakeholder groups should be included in the CPF, especially the youth and women.
The determination of stakeholders has often been a contentious issue in most communities. A truly representative forum is the one that seeks membership beyond party political affiliation, that encourages and actively devises ways to include women, youth, professionals, domestic workers (appropriately called domestic maintenance coordinators) or their representatives, people in rural areas and farms workers, etc. All the stakeholder groups must be invited to an initial meeting where the purpose of the CPF is discussed with the view to soliciting and assessing the need for broader participation. CPFs ought to be inclusive of all sectors of the community.
Police representation in the forums should be reflective of the demographic situation at the police station.12 Low ranking officials should also be represented or encouraged to participate actively in the CPF as they have a direct contact with the community they serve on a daily basis. The rank and command structure of the police service tends to hinder effective and informal communication among police personnel. The culture of the police force, in the past, emphasised the respect for authority and command. The command structure was very rigid and did not make room for social interaction among the police. The police personnel have always insisted on being called by their ranks and not their first names. Thus, a subordinate cannot criticise or question his or her senior. Such behaviour is often seen as lack for discipline and is punished. However, the participation of police personnel, irrespective of the rank, in CPFs requires active participation and critical analysis of the situation in which policing happens.
A representative CPF stands a better chance of gaining broader community support. The existing forums battle to gain the support of the broader community and should review their composition, modus operandi and incorporate other role players in the community.13 Once representivity has been achieved, it is essential for the CPFs to maintain consistent representation to ensure continuity, accountability of representatives to their constituencies and commitment to the duties of the CPF. In areas where representation seems tedious and unworkable, representivity should be decentralised by establishing sectional and block representation. This kind of representation has become a tradition in most historically black areas and ensures local accountability and accessibility to decision-making structures.14
Reporting Back to the Community and the Police
The report back mechanisms of many CPFs have been grossly ineffective. This is due largely to representatives of organisations not giving feedback to their constituencies on the activities of CPFs, of the police representatives not giving adequate feedback to the low ranking officials especially the constables who are in daily contact with the community and of the CPFs not reporting to the community and broader public on their activities. Lack of consistency in attending these forums has also contributed to the poor feedback or its absence. Poor feedback to the community has a negative impact on community involvement in CPF activities. The provision of feedback to members of the police and the community, who are not part of community police forums, could take various forms.
Community meetings as sports stadiums provide CPF members the opportunity for close interaction with community members who may otherwise have little contact with them or do not know them.
Distribution of pamphlets and newsletters
This will improve communication between the CPF, the community and the police. However, the language used in these pamphlets should be accessible to the target audience, especially in those communities where the literacy level is low. Pamphlets and newsletters are effective in areas where most people can read and write. When used in areas where some people cannot read and\or write, they must be accompanied by mass meetings where people can ask questions or comment on the issues raised or presented by the CPF.
The placing of suggestion boxes in places such as shops, police stations, libraries, schools, sports fields and other community centres could further enhance communication with different audiences.
Community radios are an emerging trend and reality in most communities. These could service CPFs and help publish their work through interviews with CPF members, news broadcast and talk-back shows. Most people listen to radios than read newspapers, especially in areas where the literacy level is very low.
The concern about the late reporting of crime to the police highlights a dire need for an awareness programme for the community on the procedure of reporting crime and the urgency of doing so in order for the necessary investigation to ensue without delay.15 While the community shares the responsibility of reporting crimes and giving evidence in court, the community is concerned with the lack of a witness protection programme for those members of the community who witness crimes, but fear reprisals and thus do not report crimes.16
Witness protection programme
The current witness protection programme is both inadequate and ineffective and should therefore be reviewed as a matter of urgency. A comprehensive and witness friendly protection programme should be developed to boost the confidence of those victims or survivors of criminal acts or violence who are still reluctant to report crimes due to fear of intimidation and potential harm unto themselves.
The police and CPFs can look at the witness protection programme used in the Goldstone Commission, the newly developed one to be used by the Truth and Reconciliation Commission (TRC) as well as those used in other countries as we are now part of the global village.17 A comprehensive witness protection programme will contribute to an increase in the reporting of crime and thus assist in providing a true reflection of the crime situation in the country because in the past, and to some extent even today, the official crime statistics did not provide a true picture of the crime situation.18 However, an increase in the reporting of crime does not necessarily mean that crime is on the increase, but that more crimes are being reported. With the changing socio-political context and the improvement in community-police relations, the reporting of crime is expected to rise exponentially.
Criminal justice system (process)
The emerging trend in the reporting of crime will test the efficacy of the criminal justice system or process. In its current form, the criminal justice system or process is less likely to deliver to the expectations of communities and will therefore result in heightened tensions between the community and the various components of the criminal justice system or process. This could result in community members and groups not reporting crime because they could believe that animals will be prosecuted. Most community members do not perceive the problem holistically, but attribute it to either the police, courts (justice system) or prisons (correctional services).
The response rate of the police is, in most cases, very slow and appalling. This could be due to a wide range of factors such as lack of human and logistical resources.19 However, the inability of the police to respond quickly to the complaints has a damaging effect on both the image of the police (as people become less inclined to report cases as a result of the poor response rate) and on the embryonic relationship that is beginning to bear positive results. Although the immense difficulty of obtaining more logistical resources for the police is understandable, the safety and security of communities remains paramount. Nonetheless, the response time can improve when certain actions can happen.
These include the need for a "house number and street name" campaign, especially in those areas where these do not exist or where they are few.20 The numbering of houses and the naming of streets will enable the police to easily tack down suspects and to be able to respond to complaints as well as to visit the complainants to report on the progress of cases reported.
The new approach to policing will address the concern raised about the failure of some members of the police, including members of the specialised units, to produce search warrants when conducting raids. The police should be obliged to wear name tags or to produce the official identification badges. Moreover, they should follow proper search and seizure regulations specified in the Police Act. This procedure will serve to ensure that the police do not abuse their powers and are not accused of misconduct because they will be known and accountable to the community they serve. Moreover, this method of policing will address allegations of harassment of community members by the police. Allegations of police misconduct, corruption and complicity in crime should be thoroughly investigated and those implicated in such acts be suspended until their cases are resolved.
Civilian oversight over investigation of allegations against members of the police service is critical and should be independent of the police. Police officials that are implicated in criminal acts should not be transferred to other police stations, police headquarters or provinces. If posted to other areas during the investigation, this will set a bad precedent and serve to undermine the transformation process as well as to dampen the confidence of the community in the police service as a whole.
Lack of visible policing poses a major problem to the safety and security of communities and affects the efficacy of the police service. Rather than increasing the number of the police officials within the police service, which is already bloated, it is essential that the police improve the utilisation of personnel. The effective utilisation of human and logistical resources is very crucial for establishing an effective and efficient police service.21
Visible policing can be improved by employing qualified civilians to do administrative duties and thus enable the police to carry out the operational duties, that is, professional police work.22 The majority of the police are confined to police stations, provincial and national headquarters instead of patrolling the streets and apprehending criminals and suspects. The police service requires a sound human resource management strategy which places much emphasis on the effective utilisation of personnel. The development of such a strategy will improve the efficacy of the police manifold. Moreover, the employment of civilian personnel will contribute to the demilitarisation of the police institution.
More police, less crime syndrome
With the police service of over one hundred and forty-five thousand members, the largest in the continent, the increase in the police service will not necessarily reduce the rate of crime in the country as has been the case in countries such as Britain and United States of America where the increase in the number of police was coupled by an increase in the crime rate. Instead of increasing the number of police personnel, the police management and the government should improve the working conditions of the police including their remuneration (salary) packages. A motivated, content and competent police service will clamp down on crime and will not be tempted to engage in criminal activities as is often the case, currently. An improvement in the visibility of the police service will facilitate and enhance the accountability and transparency of the police service and thus contribute positively and substantially to the transformation of the police institution.
Courtesy visits by members of the police after making arrests will further ameliorate the image of the police, boast the confidence of the community in the police and promote accountability of the police to the community. The police have a major role to play in changing the perceptions of broader public for them to get cooperation form communities, where such cooperation do not exist.
Sustainability of CPFs
The government allocated a budget of three million rand to each MEC for Safety and Security, in the absence of provincial commissioners,23 to assist mainly with the sustainability of these forums. The bulk of the money was spent on the running costs incurred by the CPFs. A criteria for dispersing the money was derived at between the MEC, in Gauteng, and the chairpersons of CPFs as to which CPFs should receive the financial assistance because the money allocated was very little to cater for all the CPFs in the province. This once-off payment of about five thousand rand will assist CPFs with their day-to-day functioning and hopefully empower them to initiate projects and to improve their general functioning.
However, it is by no means adequate for the medium- to long-term sustainability of these forums. Many CPFs will have to raise and generate funds. CPFs in historically white areas had begun fund-raising campaigns and thus initiate projects to combat crime. These forums are not entirely dependent on state funding. However, CPFs in historically black areas are battling to raise funds mainly because the communities in which they are located are either poor or have limited resources.
Enskilling and empowerment
The sustainability of community police forums is not only dependent on monetary assistance, but also on the skills which will enhance the functioning of these forums. Some of these skills, once acquired, will enable the CPFs to sustain themselves and be able to raise funds on their own. To be able to raise funds, forums should begin to draw up budgets for the functioning of CPFs. There are two kinds of skills that are essential for the proper running of the CPFs. First, CPFs require skills such as conflict management and resolution, organising, mediation, facilitation and networking. These skills are particularly necessary in those areas which are still experiencing relationship problems between the police and the community and in those places where the level of community participation in CPF activities is very low or non-existent. Second, CPFs require skills that will enhance the efficacy of the CPFs and these include project management, financial management, co-ordination (campaigns and project), para-legal (for formulating contracts), fund-raising, networking with key role players in government and commerce, chairing meetings and administrative.
Community police forums often function in isolation and do not share experiences, except at conferences and workshops. CPFs need each other for their existence. A good example is the Bramley/Alexandra situation whereby the Bramley CPF gave its monetary contribution from the government to the Alexandra CPF.
Relationship with Other Forums in the Community
The CPF should establish relationship with other forums that are operative in the community. Many communities have forums such as the Reconstruction and Development Forums, Development Forums as well as other structures such as the local government's safety and security structures. The various forums and structures present both opportunities and threats to the proper functioning of CPFs.24 It is essential for CPFs to form strategic alliances with various key stakeholder groups in the community in order to avoid tensions over contentious issues emanating as a result of working in the same environment. On the one hand, for the Reconstruction and Development Programme to succeed, safety and security considerations are essential because development tends to generate more conflict in under-resourced areas where people could vie for scarce resources.25 On the other hand, for community policing to succeed, the construction of tarred roads and the installation of adequate lighting, inter alia, are essential. Therefore, there is a symbiotic relationship between CPFs and local government which needs to be harnessed and sustained.
Deployment and Distribution of Resources
The distribution of resources within the police service is uneven. There are more police resources in historically white areas than there are in historically black areas. The gross inequalities and discrepancies that exist are a result of the legacy of the successive apartheid regimes. The challenge facing the police service is to redress this gross imbalance so that those areas that were disadvantaged because of apartheid policies and practices are better resourced. The process of redressing the inequitable distribution of resources requires careful planning and sound policies because the haphazard and poorly planned redistribution of resources could raise tensions and divisions within the police service.
The reallocation and redistribution of resources from well off areas to worse off areas should not be seen as empowering historically black areas at the expense of disempowering historically white areas. This is not merely a situation of "taking from Paul and giving to Peter". It is submitted that not all historically white areas are exceptionally resourced. However, there are areas which have adequate resources to police their areas effectively and could offer some of the resources without affecting policing in those areas. For example, the Tembisa police station has one police station and services an estimated population of 1.2 million people whereas Kempton Park has ten police stations, including satellite stations, and services an estimated population of eight hundred thousand people.
Most specialised units are situated in historically white areas and very few, if any, are situated in historically black areas. Most police stations in historically black areas only have the uniform and in the case of bigger stations also the detective branches. The remoteness of specialised units from the historically black areas has, in some instances, resulted in mistrust and hostility towards these units. The Internal Stability Unit (ISU) has, in the past, become very unpopular in the townships, for example. The specialised units should be decentralised and situated in many police stations, especially in historically black areas. This will also serve to build trust and confidence in these units.
Many satellite stations in the historically black areas service very large populations and do not have adequate resources. These satellite stations are worse off than those in historically white areas. Most satellite stations could be upgraded, where possible, into fully fledged police stations with various divisions and resources. More police stations are needed in areas where very few or none exists, especially in the informal settlements. The police station in Orange Farm is a kilometre away from the community it serves. This impedes the desired relationship between the police and the community.
The distribution of resources is geographically skewed, as well. The police stations in the Pretoria are better resources compared to other areas. Johannesburg is second to Pretoria in this regard. Proximity to national and provincial police headquarters appears to be a factor in as far as resource allocation is concerned. Areas with a large proportion of rural or peri-urban settlements tend to be worse off than those near or in towns and cities. The West Rand, Vaal and parts of East Rand and Soweto are worse off.
There is also a very high percentage of lower ranking officials in the police service, especially at the rank of constable. The inclusion of the former municipal police has increased the number of constables. This situation has severe implications for the police service. First, very few people in management ought to supervise large groups of people. Second, lower ranking officers who were disadvantaged in the past would seek promotion on the basis of the length of service. Third, the police service will certainly spend more money training and re-training personnel who will form part of junior, middle and subsequently senior management.
The geographically and racially skewed distribution of resources needs to be investigated and redressed in order to achieve effective policing in Gauteng. Lack of resources, particularly in those areas which have a greater need for effective policing poses major challenges for the successful implementation of the community policing philosophy in South Africa. The police needs to keep proper and accurate audits of their resources. Elaborate planning and careful prioritisation of activities would, in consultation with community and other interested and affected stakeholders, further enhance the efficient and effective utilisation of scarce resources. Thus, Gauteng would require a sound resource management strategy as well as periodical evaluation and monitoring of both human and logistical resources. Moreover, the police station management should be trained in resource management.
The crime hysteria feeds on several assumptions which needs critical examination. First, there is an assumption that the number of police personnel in relation to the population is grossly inadequate. What is not made clear is the proportion of criminals in relation to the number of law abiding citizens? Are we saying that the number of criminals far outweighs that of law abiding citizens or are we saying everyone, including the president, is a potential criminal? Second, there is an assumption that the police have few logistical resources. The utilisation of these resources is often a problem. Communities complain of police misconduct which range from drinking while on duty, police vehicles parking at shebeens when there are no conflicts to reckless driving which results in many police vehicles either damaged or involved in accidents. The police seem to be failing to discipline and discourage misconduct. Third, will the provision of more vehicles, for examples, result in more arrests and the reduction in crime or in the increase in misconduct and abuse of these resources. Foot, horse, bicycle or motorbike patrols, where feasible and appropriate, could result in more visibility and closer contact and interaction with community compared to fast racing cars. The police needs to be innovative in the efforts to combat crime. One may ask, what is new in the police methods of combatting the new wave of crime? Very little innovation and creative thinking is involved, particularly at a local level.
Fourth, there is a mistaken believe and perception that policing is what the police do. There is more to policing than what the police do. Policing is not the exclusive reserve of the police. There are many stakeholders in policing and these include, inter alia, private security companies; neighbourhood, business, block, yard and street watches; CPFs; youth defence structures (SDUs, SPUs and Task Forces); Makgotlas; NGOs and tertiary education institutions working in the field of policing, human rights and violence; interested and affected individuals; and political and community organisations. Therefore, there are many people in various formations who contribute to the safety and security of communities in addition to the police. The police need to include these stakeholders in its project planning and implementation phases to ensure sustainable progress and effective crime combatting strategies and action plans.
3 The Change Managements Team's Technical Team on Community Policing has produced a discussion document on Community Policing. This document and others on community policing should be made accessible to CPFs.
5 Some CPFs and police stations have been instrumental in initiating and organising joint community-police social, cultural and other activities. However, the community should be fully involved in the planning and implementation phases. In most cases, the community is expected to support such occasions by merely attending. Meaningful community participation entails both planning (decision-making) and implementation (execution of decisions made jointly).
7 This could serve to address the police and courts' concern about the lack of sufficient evidence to prosecute due to lack of witnesses. Such joint activities will also give the community the collective voice in persuading the courts to prosecute.
9 Community members should be able to pay courtesy visits to police stations. The image of police stations affects this interaction. The community should reclaim police stations as institutions that are there to serve their needs and interests.
13 A CPF could seek the services of professionals such as social workers, lawyers and accountants who reside in the community and may not be organised as a group. It could request such individuals as members of the community to render a particular service as part of community service. CPFs should use the community as a resource and not depend entirely on outside help.
Therefore, CPFs should adopt flexible criteria on who should attend meetings. Our experience is that a great many people want to contribute to the policing of their areas, but the often rigid membership criteria stifles their creative and innovative contributions and they become despondent and disillusioned about policing. This should not be perceived as advocating for unrestricted, big and inefficient CPF meetings, but to utilise resources in the community optimally.
14 Decentralised representations could retard speedy decision-making because the process of consultation could take long to materialise. However, such a representation ensures greater participation in decision making. Thus, one should strike a balance in this regard.
18 The crime statistics are often used for different interests or agendas by various groups, including the police. It is submitted that the interpretation of crime statistics is subject to abuse. Crime information and statistics require deconstruction, contextualisation and careful analysis. The presentation of crime information (figures) tends to sensationalise serious issues. It also dehumanises victims and survivors of such acts, which are mostly violent and traumatic.
19 The effective management of resources (both human and logistical), which, inter alia, entails the redistribution of such resources to needy areas, will lead to improved performance. More resources do not necessarily result in the reduction of crime. Also see Rauch, "The community must police", Sunday Times, 29 October 1995.
21 While the police complain about lack of resources such as vehicles and person power, there are complaints from community members about police officials utilising police vehicles for private use; police vans which stand outside shebeens with no crime or violence reported; police drunk during working hours and acting rudely towards the community.
While corruption in the police service is still rife, there shall be no vehicles and people to attend to complaints.
22 Many police officials, especially senior police are overwhelmed by stacks of labourious paper work while the crime rate is soaring daily. The police should do what they were trained to do, to apprehend criminals and to protect law abiding citizens.
23 The Provincial Commissioners were appointed long after the MECs were appointed. In the absence of the provincial commissioners, the MEC became responsible for the setting up of CPFs in their provinces.
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