13 7. In casu, how can the age of marriage be different and how can it be justified? I. CONCLUSION 138. It is respectfully submitted that justice requires that the Court issue a declaratory ()rder to the effect that all marriages in Zimbabwe cannot then take place with minors. More importantly, the Court must declare Section 22 of the Marriages Act null and void as well as the Customary Marriages Act to the extent that it does not proscribe the age of eighteen ( 18) and above as the age of marriage. 139. It is so submitted. DATED AT HARARE ON THIS 1" DAY OF DECEMBER 2014 TENDAI BITI LAW Applicants' Legal Practitioners HMB CHAMBERS 28 Rowland Square Milton Park HARARE [TB/om/V2l To: THE REGISTRAR Constitutional Court HARARE And To: CIVIL DIVISION OF THE ATTORNEY GENERAL'S OFFICE Respondents' Legal Practitioners 2"d Floor, Block 'A' New Government Complex Cnr. Samora Machel Ave/Fourth Street HARARE [4/JUSTICE/985 MC/ccl Page 46 of 46 Applicant's Heads of Argument in the matter between: Loveness lvludzuru & Another v Minister of Justice Legal & Parliamentary Affairs & 2 Others Case Number CCZ 79/2014 Prepared byTendai Biti Law