General 1993 (1) ZLR 242 (SC); Zara v Principal of Belvedere Technical College & Another 1997 (2) ZLR 508; Mandizvidza v Chaduka NO & Others 1990 (2) ZLR 375; Nyambirai v National Social Security Authority & Another 1995 (2) ZLR 1 (S). 46. Counsel has had occasion to study the Mawarire judgment, and the Heads of Argument that were presented by Counsel in those matters. Counsel Regrettably, none of the heads of Argument filed by addressed, interpretation. the question of Constitutional Only the heads filed by Counsel for the Third Respondent, Mr T abani Mpofu, had a casual reference to statutory interpretation. Unfortunately that was only restricted to Fieldsend CJ' s judgment in the Hewlett matter referred to above. Counsel has no doubt that it is now time that this court, fully addresses itself on the key question of Constitutional interpretation. 4 7. In short it is submitted that a broad generous purposive interpretation ought to be applied. LOCUS STANDI 48. The Respondents take a very deem v1ew of the issue of Constitutional locus standi which even in the old position of teh repealed Constitution this Court had already rejected. 49. The old common law principles required that for an individual to have locus standi he should show some legitimate interest in the matter. Page 19 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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