"81. Rigl1ts of children ( 1) Every child, that is to say every boy and girl under age of eighteen years, has the right (a) To equal treatment before the law, including the right to be heard; (b) To be given a name and family name; (c) In the case of a child who is (i) Born in Zimbabwe; or (ii) Born outside Zimbabwe and is a Zimbabwean citizen by descent; to the prompt provision of a birth certificate; (d) To family or parental care, or to appropriate care when removed from the family environment; (e) To be protected from economic and sexual exploitation, from child labour, and from maltreatment, neglect or any form of abuse; (f) To education, health care services, nutrition and shelter; (g) Not to be recruited into a militia force or take part in armed conflict or hostilities; (h) Not to be compelled to take part in any political activity; and (i) Not to be detained except as a measure of last resort and, if detained(i) to be detained for the shortest appropriate period; (ii) to be kept separately from detained persons over the age of eighteen years; and (iii) To be treated in a manner, and kept in conditions, that take account of the child's age. (2)A child's best interests are paramount m every matter concerning the child. Page 23 of 46 Applicant's Heads of Argument in the matter between: Loveness Mudzuru & Another v Minister of Justice Legal & Parliamentary Affairs & 2 Others Case Number CCZ 79/2014 Prepared by Tendai Biti Law