Judgment No. CCZ 5/15 10 Const. Application No. CCZ 23/14 TOBAZ. This deficiency is critical insofar as TOBAZ purports as it does to represent the interests of the motoring public. To sum up, I take the view that the applicant has dismally failed to establish the requisite locus standi to act in this matter in the interests of its own members or in the interests of any class of persons or in the public interest. Entitlement to Relief Sought Notwithstanding the above conclusion on the absence of locus standi, I shall proceed, for the sake of completeness, to address the propriety of the relief sought by the applicant in the context of the Insurance Act and the regulations made thereunder. Apart from the constitutionality of the 2010 agency agreement, TOBAZ also questions its legality under the Insurance Act, in particular as regards the status of ZIMRA as an insurance agent. Advocate Magwaliba, for the respondents, argues that there is no statutory registration requirement in respect of an insurance agent such as ZIMRA. He also argues that the members of TOBAZ have been operating as unregistered insurance brokers in clear contravention of the Insurance Act. It is necessary to examine both of these aspects, even though they are incidental to the constitutional issues before the Court. An “insurance agent” is defined in s 3 of the Insurance Act as a person who, on behalf of a registered insurer, initiates insurance business or does any act in relation to the