(a) if the client consents to disclosure or waives the privilege; or (b) if the confidential communication was made to perpetrate a fraud, an offence or an act of omission rendering a person liable to any civil penalty or forfeiture in favour of the State in terms of any enactment in force in Zimbabwe; or (c) after the death of the client, if the disclosure is relevant to any question concerning the intention of the client or his legal competence. (6) Any evidence given in contravention of this section shall be inadmissible. It is quite clear from the cited authorities and section 8 of the Civil Evidence Act that the sanctity of lawyer-client privilege is largely applicable in the domain of litigation or court proceedings. Indeed a proper reading of s 20 of the Constitution reveals that the lawyer-client privilege, as such, is not constitutionally guaranteed. It is only constitutionally guaranteed to the extent that the lawyer-client privilege is subsumed in the right to freedom of expression which includes freedom from interference with one s correspondence. I have no doubt that a breach of the lawyer-client privilege almost invariably leads to the violation of one s entitlement to a fair trial guaranteed under s 18 of the Constitution but that is not the basis of the present application. ARE SECTIONS 98(2) AND 103 OF THE ACT INCONSISTENT WITH SECTION 20 OF THE CONSTITUTION? Section 20 of the Constitution provides as follows:20 Protection of freedom of expression (1) Except with his own consent or by way of parental discipline, no person shall be hindered in the enjoyment of his freedom of expression, that is to say, freedom to hold