adequate notice before demolitions. From the investigations conducted, the ZHRC established that the complainants were given seven days verbal notices to vacate the Estate yet there was no court order to that effect as specified by Section 74 of the Constitution. The right to administrative justice was therefore violated. 6. CONCLUSION Evictions of illegal settlers continue unabated in Zimbabwe. This is largely due to the fact that Zimbabwe does not have rules and regulations on the eviction procedure of both former farm workers and illegal settlers on agricultural land (former white commercial farms). Therefore, in the present case, although the complainants were illegal settlers and could not hold or have right of title to the farms (through possession of Offer Letters), their eviction from farms without any alternative land being offered is a violation of their right to adequate shelter and their freedom from arbitrary eviction without considering all the relevant circumstances. 7. RECOMMENDATIONS In light of the above findings and conclusion, the ZHRC makes the following recommendations: TO and PARLIAMENT OF ZIMBABWE 11.1. To ensure a law is enacted that curb illegal grabbing and invasion of farms; 11.2. To enact laws that specifically deal with the eviction of illegal settlers from farms; 11.3. To enact laws that protect the rights of former farm workers. MINISTRY OF LANDS, AGRICULTURE AND RURAL RESETTLEMENT 11.4. To find a way of finalising and ensuring that the Land Reform does come to an end; and 11.5. To provide shelter for evicted illegal settlers. Page 6 of 6