standards established by competent authorities, particularly in the areas of safety, health, in the number and suitability of their staff, as well as .. " competent supervrswn. 72. The same concept is also recognised in the OAU Charter on the Rights of the Child. 73. In this regard the 199 5 UN Convention on the Rights of the Child, and the African Charter on the Rights and Welfare of the Child are key instruments in protecting the rights of children. 74. Zimbabwe still has a long way to go before it adopts a separate child protection legislation to follow what is common in other jurisdictions for instance in South Africa where they have a Child Care Act No. 74 of 1983. This law is overdue. 75. It is submitted that allowing children to be married is subjecting the same to maltreatment, neglect or any form of abuse which is proscribed in Section 81 (1) (e). 76. If our Courts have held that child whipping is unconstitutional. See State v Williams & Others 1995 (3) SA 633 (CC)~ surely it must find early marriages being a total form of complete abuse. 77. Equally an important provision relevant to this matter is the right of children to family or parental care codified in Section 81 (1) (d). 78. Unlike the South African Constitution, the Zimbabwean Constitution, defines the issue of family and family protection as an obligation on the State. Section 19 of the Constitution reads as follows:, Page 26 of46 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 byTendai Biti Law