Comparative analysis reveals how public challenges shape oversight outcomes in South Africa, Zimbabwe, and the UK, suggesting effective learning tools.
This article compares three episodes during which publics challenged digital surveillance: (1) post-Snowden campaigns around the United Kingdom's Investigatory Powers Act; (2) South Africa's litigation over the Regulation of Interception of Communications and Provision of Communication-Related Information Act linked to the #ZumaMustFall protest cycle; and (3) Zimbabwe's 2019 internet-shutdown challenge. Rather than ranking countries, the paper traces how oversight worked in each episode – what actors did, which messages resonated, and how institutions responded. Using process tracing and thematic coding, the study identifies two recurring mechanisms connecting contention to oversight outcomes. First, legal-institutional pipelines can secure incremental but durable reforms, though gains often remain concentrated among specialist organisations. Second, coalition expansion through anti-corruption framing and diaspora amplification can widen participation, sustain lawfare in moments of crisis, and translate scandals into institutional pressure for reform. A decolonial lens supports two-way learning between campaigns in the United Kingdom, South Africa, and Zimbabwe.
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Daniele-Hadi Irandoost (2026) studied this question.
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