Comparative analysis reveals differing outcomes of public oversight in Botswana and Mauritius, indicating that grassroots engagement is crucial for reform.
This article examines why public oversight of intelligence-driven digital surveillance produced divergent outcomes in Botswana and Mauritius – two African democracies with comparable political and socio-economic contexts. Using Resource Mobilisation Theory and Political Process Theory within a Most Similar Systems Design framework, the article compares mobilisation strategies against the 2013 biometric Smart ID system in Mauritius and the 2022 Criminal Procedure and Evidence Bill in Botswana. Although the cases involve different policy instruments, both constitute forms of state-led expansion of surveillance authority, thereby providing equivalent sites for analysing public oversight responses. Mauritius saw broad-based mobilisation – including grassroots actors, legal experts and media – which led to successful policy and legal reforms and the dismantling of a central biometric database. In contrast, Botswana's mobilisation was elite-driven and achieved only limited amendments, constrained by weak civil society, limited public engagement and executive dominance. This article demonstrates that the success of public oversight in confronting surveillance abuses depends on the degree of grassroots participation, the ability to form coalitions with diverse actors, and the structural and cultural contexts that enable or hinder mobilisation. It highlights the necessity of inclusive, broad-based public engagement for achieving meaningful reforms in state surveillance practices.
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Chiumbu et al. (2026) studied this question.
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