Zimbabwe Rule of Law Journal |39 to provide that the Judicial Service Commission, with the approval of the Minister responsible for justice may make regulations. Moreover, section 190(4) provides for the passage of an Act of Parliament that may confer on the JSC functions in connection with the employment, discipline and conditions of service of persons employed in the higher courts. These provisions have deep implications and need to be clearly analysed and examined. 1.3.1 Comment Under the 2013 Constitution, the JSC appears to be a constitutionally entrenched body responsible for matters relating to the judiciary and the administration of justice.16 It may be submitted that this entrenchment is general, not specific, and this is strongly supported by a closer reading and contextual analysis of the whole Constitution. It may also be argued that what the constitution did was to merely establish the JSC and set out its functions. The concept of constitutional entrenchment connotes inclusion of provisions in the Constitution that are deliberately and exceedingly difficult or almost impossible to amend. Section 190 that establishes the JSC is not one of the specially protected clauses or strongly entrenched clauses in the constitution such as the Bill of Rights, the land provisions as well as term limits for public office.17 Those provisions are the ‘entrenched’ provisions of the Constitution and would demand, for instance, a referendum to be changed, while the rest of the constitutional provisions including the provision establishing the JSC only require 90 days notice, public views and a two-third majority vote in parliament to be changed, an easy task if a ruling political party commands more than two-thirds majority in Parliament. To that extent therefore, the JSC is not a specifically ‘entrenched’ constitutional institution. The second point of inquiry is the mention in the Constitution that the JSC has “…all powers needed” for the purpose of discharging its constitutional mandate referred to in section 190(2). If measured against the powers of the executive, one may come to the conclusion that the JSC does not have all the powers. This conclusion can be reached after assessing the powers of the Minister and the role 16 See section 189 of the Constitution of Zimbabwe, 2013; See also Manyatera and Fombad (op cit note 6) at 19. 17 Section 328 provides for the Amendment of the Constitution.