IN THE CONSTITUTIONAL COURT OF ZIMBABWE HELD AT HARARE CASE NO CCZ 79/2014 In the matter between:- LOVENESS MUDZURU FIRST APPLICANT RUVIMBO TSOPODZI SECOND APPLICANT AND THE MINISTER OF JUSTICE, LEGAL & PARLIAMENTARY AFFAIRS FIRST RESPONDENT MINISTER OF WOMEN'S AFFAIRS, GENDER & COMMUNITY DEVELOPMENT SECOND RESPONDENT ATTORNEY GENERAL OF ZIMBABWE THIRD RESPONDENT APPLICANTS' HEADS OF ARGUMENT A. GENERAL 1. This clearly, is an important case that will stretch this Court's imagination but among other things, we will allow this revolutionary Court the Constitutional Court, to lay and define a marker with regards to the following issues:~ (a) The approach to interpreting the Bill of Rights; (b)The Court's treatment of children's rights and more importantly gender rights; (c) The Court's treatment of the key subject of equality and discrimination; (d)The adoption and absorption an application of international law and international instruments in Zimbabwe. 2. Put simply, this case allows the Constitutional Court and g1ves the same an opportunity of being bold, and setting up a constitutional trajectory or DNA in these early stages of the Constitution where the Page 1 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

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