"19 Children (1) The States must adopt policies and measures to ensure that in matters relating to children, the best interests of the children concerned are paramount. (2) The State must adopt reasonable policies and measures, within the limits of the resources available to it, to ensure that children (a) Enjoy family or parental care, or appropriate care when removed from the family environment; (b) Have shelter and basic nutrition, health care and social services; (c) Are protected from maltreatment, neglect or any form of abuse; and (d) Have access to appropriate education and training (3) The State must take appropriate legislative and other measures(a) To protect children from exploitative labour practices; and (b) To ensure that children are not required or permitted to perform work or provide services that (i) are inappropriate for the children's age; or (ii) place at education, 79. risk the physical children's or mental well-being, health or spiritual, moral or social development." Equally Section 25 of the Constitution reads as follows:- "25. Protection of the family The State and all institutions and agencies of government at every level must protect and foster the institution of the family and in particular must endeavour, within the limits of the resources available to them, to adopt measures forPage 27 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