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In October 2009 Fikile Mbalula, the deputy police minister, called for the use of firepower against armed criminals, which the media and civil society groups criticized as a police "shoot to kill" policy; President Zuma denied the charge and attributed the use of excessive force to a lack of training and resources.On September 1, the trial of Inkatha Freedom Party (IFP) member Siphamandla Mhlongo, who was being detained for the January 2009 killing of ANC stalwart Inkosi Mbongeleni Zondi, was remanded to the Scottsburg High Court, where a hearing was scheduled for February 2011.Of the 860 deaths, 479 resulted from being shot, 122 from assault, 112 due to suicide, 93 from natural causes while in custody, 27 as a result of injuries from being struck by a police vehicle, 15 as the result of an auto collision, seven as the result of torture, three from suffocation, and two from poisoning.On April 8, at a tavern in the Free State, Police Constable Elliot Khaka shot and killed Sombane Lungile after Lungile allegedly attempted to steal a car belonging to another constable who was with Khaka.

Arbitrary or Unlawful Deprivation of Life Unlike in the previous year, there were no reports of politically motivated killings by the government or its agents; however, police use of lethal and excessive force, including torture, against suspects and detainees resulted in numerous deaths and injuries.

On November 15, the Free State High Court convicted Khaka of murder and sentenced him to 12 years' imprisonment.