23. The above submissions on this subject are being made to underscore this Honourable Court, the fact that it is indeed an ultimate authority on its own standing on par with legislature and the judiciary. But more decisively when it comes to the questions of constitutionalism, the rule of law, legitimacy, democracy and accountability, and the separation of powers, the position of the Constitutional Court is superior position than any of the other branch of the State mentioned above. 24. Having stated this, it is now proposed to deal with some general pointers on constitutional interpretation which it is urged at this Honourable Court. D. POINTERS TO INTERPRETING THE BILL OF RIGHTS 25. The manner in which the Constitution itself is interpreted in particular the Bill of Rights denotes and requires the imperator that the Courts must develop new clear and precise jurisprudence. 26. It is respectfully submitted that on the basis of a clear analysis of the law as propounded in the House of Lords, the Privy Council, the Canadian Supreme Court, the South African Constitutional Court and the Indian Constitutional Court that Zimbabwe will not have to reinvent the wheel and that the following principles which will be covered briefly in these heads must guide this Court in the interpretation of the Bill of Rights. 2 7. Put differently, it is submitted that the Constitutional Court must be interpreted on the following principles:~ (i) That it must be interpreted progressively; Page 7 of46 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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