land which they occupy, without the provision of, and access to, appropriate forms of legal or other protection”. In this case, complainants were being removed against their will but they had access to appropriate forms of legal protection since they approached the ZHRC and later the courts which granted an interdict against Respondent thereby stopping their eviction without a court order. 4.3 The African Union Convention for the Protection and Assistance of Internally Displaced Persons in Africa, which Zimbabwe ratified, requires in article 3(1) (a) states parties to “refrain from, prohibit and prevent arbitrary displacement of populations.” The principles of human rights are clear that before you displace people, you need to have established alternative accommodation for them. In this case, it was clearly explained by the Respondent that no alternative land was provided to people who settled themselves on state land after the year 2000 when the widespread land invasions took place since this would encourage other people to settle themselves on state land without offer letters or permits. Whether or not the right to adequate shelter was violated 4.4 Section 28 of the Constitution states that: “The State and all institutions and agencies of government at every level must take reasonable legislative and other measures, within the limits of the resources available to them, to enable every person to have access to adequate shelter.” This implies taking measures to provide alternative shelter to evictees. Failure to take such measures constitutes a violation of the right to adequate shelter. 4.5 This provision is analysed taking into consideration the fact that the villagers settled themselves on state land without offer letters or permits. 5. Whether or not the right to administrative justice was violated 5.1 Administrative justice in terms of Section 68 of the Constitution requires that any administrative action be fair, reasonable and procedurally fair. Procedural fairness includes, in this present case, giving complainants Page 5 of 6