Judgment No. CCZ 7/2014 15 Const. Application No. 41/2014 render the eventual relief ineffectual. See Pickering v Zimbabwe Newspapers (1980) Ltd 1991(1) ZLR 71(H); Dilwin Investments (Pvt) Ltd v Jopa Engineering Company (Pvt) Ltd HH116-98; Triple C Pigs & Anor v Commissioner General, Zimbabwe Revenue Authority 2007(1) ZLR 27(H). An examination of the founding affidavit reveals that the applicant basis its claim for an order that the main application be heard on urgent basis on the allegation that the respondent wrongly assessed its tax liability. The allegation is that payment of the tax will destroy the applicant’s business. The applicant sees in the appeal before the Fiscal Appeal Court, or the constitutional proceedings a remedy that will secure for it, immediate release from the burden of having to pay tax it claims is not due to the fiscus. The certificate of urgency gave as grounds for having the matter treated as urgent the tax recovery measures the respondent was about to put in place. It also alluded to the need to prevent financial hardships the applicant would suffer as a result of payment of the tax. Paragraphs 5 and 6 of the certificate of urgency refer to the threatened tax recovery measures and their possible effects: “5. This collection is imminent and due to happen any time soon and if it happens not only will the outcome of the appeal be rendered academic but the collection may quite literally destroy Applicant’s business in such a manner that Applicant will never recover even if the appeal is successful. This is especially so given the huge amounts of money involved. 6. Whilst the need for Respondent to be able to collect taxes efficiently and effectively is acknowledged, it is imperative that this Honourable Court clarify the constitutional issues that are raised by Respondent’s arbitrary and summary procedures