mental harm'; lost opportunities, including employment, education and social benefits'; 'material damages'; and 'costs required for legal or expert assistance, medicine and medical services, and psychological and social services'. Satisfaction includes a 'public apology, including acknowledgement of the facts and acceptance of responsibility'. With regards the inadequate legal provisions, the African Commission believed the existing legislation in Zimbabwe were contrary to the spirit of Article 1 of the African Charter as it did not ensure that there were compensatory damages to give just satisfaction to victims of wrongful death particularly close family and relatives who were bereaved because of such deaths.⁶⁰ Debts owed by the government When it comes to debts owed by the government, enforcement of judgments in Zimbabwe is difficult. It largely depends on whether the government has the financial resources to settle. For as long as government pleads that it does not have the resources, the only reason for proceeding against it in court is to just hold onto the judgment until the day government declares that it now has the capacity to settle. On March 15, 2017, Justice Mushore delivered a landmark judgment⁶¹ that struck down Section 5(2) of the State Liabilities Act (Chapter 8:14) — the law which made State assets untouchable — saying it was unconstitutional. The development puts every piece of government asset together with those of its companies and other departments — both movable and immovable — at risk of seizure by the creditors. Section 5 (2) of the State Liabilities Act (Chapter 8:14) was declared to be inconsistent with the Constitution of the Republic of Zimbabwe and therefore invalid. The judge noted that: If Section 5(2) is being used to frustrate justice as is clearly the case in the present case, then it is not justifiable in a democratic society based on openness, justice, fairness, human dignity equality and freedom … If those rights are impeded, the Declaration of Rights implementation is severely impeded.”⁶² However, in July the Constitutional Court of Zimbabwe invalidated the ruling on a technical basis arguing that the High Court Judge who invalidated the Act should not have referred the matter to the ConCourt. Chief Justice Luke Malaba noted on 12 July 2017, that the judge had no legal basis to make that order of referral to the Constitutional Court and therefore, all the processes starting from the judge up to this day were a nullity. The Forum laments such kinds of decision that trump decisions by lower courts on the basis of technicalities. The fundamental issues that led to the offensive law being challenged does not go away and remains valid in the process impinging on the human rights of citizens. State Liabilities Act frustrating victims and survivors For many cases of politically motivated and state sponsored violence in Zimbabwe, the people that died were breadwinners in their families and mostly men. Children were left orphans with no one to pay for their school fees, food and other needs.⁶³ To demonstrate sincerity, the government of Zimbabwe should ensure that proper research is carried out by a body such as the National Peace and ⁶⁰ African Commission case at para 143. ⁶¹ Mangwiro V Minister of JLPA 1 HH 172-17 - HC 6960/16 ⁶² Tendai Blessing Mangwiro v. The Minister of Justice and Legal Affairs (NO) and 2 Others, HC 6960/16 ⁶³ See Zimbabwe Human Rights NGO Forum reports. Anti-Impunity Report 31