the war veterans and ZANU-PF have justified the chaotic invasions as the Third Chimurenga (liberation struggle). In the absence of the rule of law, it has been difficult to stop these invasions and uphold property rights. Since 2000 ZANU-PF has capitalized on the land reform for political mileage. In the 2000 parliamentary elections, ZANU-PF campaigned with the slogan “Land is the Economy and the Economy is Land.” In the 2008 elections the ZANU-PF manifesto was '100% Total Empowerment and Independence', thus using the land issue to achieve their political agenda. A number of pieces of legislation continued to be enacted. The Citizenship Amendment Act Number 12 of 2001 introduced a prohibition on dual citizenship so that people with dual citizenship would automatically lose their Zimbabwean citizenship unless they renounced their foreign citizenship. This affected 30% of farm workers who originated mainly from Malawi and Mozambique and disenfranchised most white Zimbabweans, the majority of whom held foreign passports. In addition, under current law almost all farmland is now regarded as state property. This was enabled by the September 2005 constitutional amendment.11 This amendment nationalized Zimbabwe's farmlands and deprived farm owners of the right to challenge the government's decision to expropriate these lands. Moreover a notice published in the Government Gazette identifying any piece of land is sufficient to transfer ownership of that land to the state. Once a farm is allocated to a new occupier, an offer letter is given. The former owner has no recourse to the courts and no right to compensation. This seems to suggest that the laws of Zimbabwe are not capable of delivering a credible land reform programme to those in need of land, nor to guarantee property rights and physical security for the land 12 owners. However, legal instruments such as the Constitution, regional and international instruments could have been used as a basis for an effective land reform programme, and for the protection of basic human rights. The problem is the unwillingness of the state to implement its own laws and abide by international obligations. The Universal Declaration of Human Rights, 1948 (Article 17) states that“everyone has the right to own property 13 alone as well as in association with others”,and that“no one shall be arbitrarily deprived of his property.” Article 14 of the African Charter on Human and Peoples Rights provides that “the right to property shall be guaranteed. It may only be encroached upon in the interest of the public need or in the general interest of the community and in accordance with the provisions of appropriate laws”.14 In Zimbabwe's land redistribution process, public interest was subdued for political expedience. Rather than permitting the full operation of the rule of law in the implementation of land reform, ZANU-PF has continued to exploit the land issue for its political mileage.15 In the process, equity, fairness, reason and rationality have been sacrificed for political expediencies. State resources and instruments, which ought to protect farmers, farm workers and their families, vulnerable to or affected by farm invasions, were mobilized to defeat the rule of law and the guaranteed basic human rights. Despite the formation of the Government of National Unity (GNU), the violent seizure of white commercial farms has continued. GAPWUZ asserts that since February 2009 almost 225 farms have been invaded. The Geneva based, Internal Displacement Monitoring Centre, points out that, since 2000 about 1 million farm workers and over 3,000 white commercial farmers have been evicted. The government has also continued to disregard court rulings on land rights. In November 2008, the SADC Tribunal ruled that the land redistribution programme was discriminatory on the basis of race and therefore contravened human rights. President Mugabe and ZANU-PF have taken the ruling as of no consequence and more so, the courts have refused to register the ruling. However, the ruling has been registered in a South African court. 11 Constitutional Amendment Number 17 2005 Land Housing and Property Rights in Zimbabwe COHRE Africa Programme Mission Report September 2001. 13 Universal Declaration of Human Rights 1948 14 African Charter on Human and People's Rights 15 See Phimister, I., & Raftopoulos, B. (2004), Mugabe, Mbeki and the Politics of Anti-Imperialism, Review of African Political Economy, 101, 127-141; Hammar, A., Raftopoulos. B., & Jensen, S. (2003), Zimbabwe's Unfinished Business: Rethinking, Weaver Press, Harare. 12 5