Judgment No. CCZ 12/2015 41 Const. Application No. 79/14 urine or faeces leakage known as obstetric fistula. This can happen when a young woman with underdeveloped physiology gives birth. In addition to their lack of power in relation to their husbands or in-laws, girls are further exposed to sexual and reproductive health problems because of their lack of knowledge, information and access to sexual and reproductive health services, in particular family planning, ante-natal, obstetrics and post-natal care. 4.9. Education Countless studies have proven that early marriage is universally associated with low levels of schooling. After marriage, young married girls’ access to formal and even non-formal education is severely limited because of restrictions placed on mobility by domestic burdens, child bearing and social norms that view marriage and schooling as incompatible. Since in most cultures girls leave their parental home upon marriage, parents tend not to invest in the education of daughters because the benefits of their investment will be lost. Child marriage and lack of access to continued educational opportunities also limit young women’s access to employment opportunities. Child marriage is also associated with early widowhood, divorce and abandonment which often results in “feminization of poverty”. Research has shown that girls with higher levels of schooling are less likely to marry as children. Elizabeth Warner observed that regardless of how it occurs, early marriage takes a terrible toll on a girl’s physical and emotional health. Because of her age, inexperience and vulnerability, she is likely to be dominated and controlled by her husband, who has the power to keep her a virtual prisoner. Rape, beatings and other forms of sexual and domestic violence are common and early and repeated pregnancies are life threatening. Young mothers also face far greater risks of complications in pregnancy because their bodies are not sufficiently developed and infant mortality is far greater among young mothers.