      Opportunity must be given for genuine consultation with those affected; Adequate and reasonable notice to all affected persons must be given prior to the scheduled date of eviction; Evictions should not take place in particularly bad weather or at night, unless the effected persons consent otherwise; Provision of legal remedies; Provision where possible of legal aid to persons who are in need of it to seek redress from the courts, including adequate compensation for property affected; Evictions should not result in individuals being rendered homeless or vulnerable to violations of other human rights. Where those affected are unable to provide for themselves, the state must take all appropriate measures, to the maximum of its resources, to ensure that adequate housing, re-settlement, or access to productive land, as the case may be, is available. In the case of Operation Murambatsvina, it would appear that the Zimbabwe Government has violated each and every one of these recommendations. However, in a recent development, saving the face of the judiciary, Justice Cheda of the Bulawayo High Court ruled that the conduct of the ZRP in destroying shacks and buildings, and in confiscating goods from vendors, was unlawful. "This conduct on the part of the police was unlawful. Police are empowered to enforce the law but can only do so within the confines of the law and not outside it. The indiscriminate and wanton destruction as described by applicant and not denied by first and second respondents cannot be allowed." 30 Rebuilding after destroying At the end of June, the Government announced the end of Operation Murambatsvina and the launch of the Z$3 trillion Operation Garikai/Hlalani Kuhle (‗Stay well‘). A number of things need to be said about this new programme. Firstly, international law provides that people should not be evicted from their homes until alternative accommodation is made available for them. In Zimbabwe, large numbers of homes were destroyed when no such alternative accommodation had been provided. Some displaced persons were taken to holding camps such as Caledonia and Helensvale, where there were almost no facilities and the conditions were deplorable. Many others had to sleep out in the open in freezing weather, and many more were simply dumped in rural areas, with no regard being paid to their welfare. Secondly, Operation Garikai was apparently not conceived prior to the commencement of Operation Murambatsvina. No budget had been provided for Operation Garikai and frantic efforts had to be found to find some money to commence this Operation. It appears to have been hastily formulated as an afterthought in order to give the impression that, right from the start, there had been a ―noble‖ objective to ensure that people no longer would live in squalor, but instead they would have decent accommodation. If this indeed had been the objective right from the beginning, surely houses would have been built first