polygynous marriages. Some widows are surprised to find that other potential wives make themselves known only upon the passing of a husband. This is a source of great uncertainty. With multiple widows competing against each other and their husband’s family for property, a larger and more complicated fight can commence for a smaller share of the property. Zimbabwe’s Dual Legal System Zimbabwe has a formal legal system that operates in parallel with customary law. Customary laws are generally unwritten but are recognized by Zimbabwe’s 2013 constitution, which defines them as “the customary law of any section or community of Zimbabwe's people.”32 Zimbabwean legal expert Slyvia Chirawu of Women and Law in Southern Africa Research and Education Trust pointed out: “[N]orms, practices and traditions … ultimately crystalize into customary law.”33 Customary law is used extensively in Zimbabwe. The Customary Law and Local Courts Act details the circumstances under which customary law applies.34 Customary law is a powerful cultural force. It is particularly potent with respect to marriage and inheritance matters for widows, but it impacts a lot of what goes on in the country. An estimated 80 percent of women in Zimbabwe “live in rural areas, marry under customary law, and do not register their marriages.”35 Customary law may hold sway over these women’s lives much more than formal, national laws. Zimbabwe officially requires the registration of two of the three types of marriages.36 But as evidenced by the high percentages of unregistered customary unions (estimated at 70 to 80 percent of women’s marriages in rural areas, according to the Food and Agriculture 32 Constitution of Zimbabwe of 2013, cap. 18, part 3, para. 332. 33 Slyvia Chirawu, “All that glitters is not gold: Challenges faced by women in implementation of laws that outlaw harmful cultural practices in Zimbabwe,” on file with Human Rights Watch. 34 Customary Law and Local Courts Act of 1997, cap. 7:05, http://www.parlzim.gov.zw/acts-list/customary-law-and-localcourts-act-7-05 (accessed January 11, 2017). 35 “Gender and Land Rights Database: Zimbabwe, Women’s property and use rights in personal laws,” Food and Agriculture Organization of the United Nations, http://www.fao.org/gender-landrights-database/country-profiles/countrieslist/national-legal-framework/womens-property-and-use-rights-in-personal-laws/en/?country_iso3=ZWE (accessed July 29, 2016). 36 See, Marriage Act, cap. 5:11, sec. 32; Customary Marriages Act, cap. 5:07 of 1951, sec. 8. 17 HUMAN RIGHTS WATCH | JANUARY 2017