A. IN LIMINE 2. I hove hod sight of the l st and 2nd Applicants' founding Affidavits and in response thereto I would like to raise the following preliminary objection. It is my respectful submission that both applicants hove no locus standi to bring this application before this honourable court in terms of section 85(1) (a) and (d) of the Constitution of Zimbabwe. 3. Applicants hove not established any causal link between them and the remedy they seek. Neither of them was married either in terms of the Marriage Act or of the Customary Marriages Act. They ore not specific to soy how they ore affected, nor do they point out which one of their specific rights hove been infringed to qualify them to bring this application in terms of section 85( l) (a) and (d) of the Constitution. In the circumstances, the Applicants ore therefore not properly before this honourable court. B. ON THE MERITS 4. Ad Paragraphs 1 - 5 This is admitted. 5. Ad Paragraphs 6- 15 I hove no knowledge of the historical background set out herein by l st Applicant regarding her personoi circumstances, but I do not deny the some. Suffice it to soy that this historical rendition does not relate to any marriage into which she entered as she has not yet married anyone. 6. Ad Paragraph 16

Select target paragraph3