Zimbabwe Rule of Law Journal |143 Further, s 74 imposes a duty on the courts to consider “relevant circumstances” before granting an order of eviction or demolition of a home although the constitution does not provide any indication of what an enquiry into relevant circumstances entails. In this respect, the South African Court jurisprudence would be helpful in ascertaining the relevant circumstances given the similarities between our s 74 and s 26 of the South African Constitution which provides for freedom from arbitrary eviction. In City of Johannesburg Metropolitan Municipality v Blue Moonlight Properties Pty (Ltd)11 the South African Constitutional Court held that relevant circumstances included legal status of the occupants; the period of occupation; and whether the eviction or demolition will leave the affected people homeless. It is however of crucial importance to note that the relevant circumstances can vary from case to case and the Court will therefore have to make a value judgment. On the same trajectory, the Constitution in its national objectives in s 28 provides that “The State and all institutions and agencies of government at every level must take reasonable legislative and other measures, within the limits of the resources available to them, to enable every person to have access to adequate shelter.” It is important to note that the right to housing is not provided in the Declaration of Rights but reference to adequate housing is made only in the national objectives in terms of the aforementioned section. Logically, one cannot seek to enforce a right in terms of s 28 which does not offer substantive justiciable rights. However, in this author’s view, the matter does not end there. The national objectives can still be invoked as an aid in the holistic interpretation of s74 in ascertaining the constitutionality of the ongoing demolitions. The Indian Supreme Court in the case of Francis Coralie Mullin v Administrator, Union Territory of Delhi,12 where the court broadly interpreted the right to life by reading into it the right to health, stated as follows; 11 12 2012 (2) SA 104 (CC) (1981) 2 SCR 516