2002. Furthermore, women are said to have been more affected by the internal displacements which occurred during the farm invasions of 2000-2005 and the urban clean-up operation known as Operation Murambatsvina. Approximately, 700 000 people were displaced during the latter exercise and a number of homes were destroyed. Most women who were involved in the informal trading sector also lost their means of livelihood. However, the classification of Operation Murambatsvina as a human rights violation is problematic since this exercise could also be interpreted as a state policy for implementing its international obligation to protect the enjoyment of the right to health. It has to be pointed out that whilst the state publicly denied any violations of human rights, it conceded liability in the confines of judges' chambers. This fact has been confirmed in the analysis of civil proceedings that the Zimbabwe Human Rights NGO Forum has been instituting on behalf of victims of state-orchestrated violence since 1998. According to their June 2006 report, 90% of their completed cases were either settled out of court or the court's findings favoured the victims. This however, cannot be seen as effective redress for victims of human rights violations in Zimbabwe since these are only those cases which were brought to the attention of the Forum. There has also not been any public acknowledgement of wrongdoing by the state. 2008 -2013 – Opportunities – the 2013 Constitution On the 15th of September 2008, following a decade of negative publicity, violence, social and economic collapse, Zimbabwe's key political parties signed a power sharing agreement known as the Global Political Agreement (GPA). Articles 6 and 7 of the GPA are worth special attention. Article 6 provided for the creation of a Parliamentary Select Committee which would lead the process of producing a “people driven” Constitution and Article 7 dealt with the promotion of “equality, national healing, cohesion and unity”. In particular, Article 7 (c) stated that the parties: Shall give consideration to the setting up of a mechanism to properly advise on what measures might be necessary and practicable to achieve national healing, cohesion and unity in respect of victims of pre and post-independence political conflicts. When the power-sharing agreement itself ended with ZANU PF's victory in the 2013 Harmonised Elections, both Articles 6 and 7 of the GPA had been implemented. This paper will not discuss the role of the Organ on National Healing and what it has achieved so far but will comment on the relevant provisions of the 2013 Zimbabwean Constitution, which relate to truth recovery. 26 The Second International Conference on Transitional Justice in Zimbabwe