(a) The State must promote the full participation of women in all spheres of Zimbabwean society on the basis of equality with men; (b) The State must take all measures, including legisbtive measures, needed to ensure that (i) Both genders are equally, represented in all institutions and agencies of government at every level; and (ii) Women constitute at least half the membership of all Commissions and other elective and appointed governmental bodies established by or under this Constitution or any Act of Parliament; And (c) The State and all institutions and agencies of government at every level must take practical measures to ensure that women have access to resources, including land, on the basis of equality with men. (2) The State must take positive measures to rectify gender discrimination and imbalances resulting from past practices and policies." 108. Further Article 56(1) & (2), of the Constitution reads as follows:~ 11 56. Equality and non~discrimination ( 1) All persons are equal before the law and have the right to equal protection and benefit of the law; Page 35 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 byTendai Biti Law