Zimbabwe Rule of Law Journal |103 The achievement of such a society in the context of our deeply inegalitarian past will not be easy, but that that is the goal of the Constitution should not be forgotten or overlooked”.39 In other words, the prevention of discrimination seeks to efficiently secure the right to equality and dignity for all as echoed by both the South African and Zimbabwean Constitutions. Therefore, the Bulawayo High Court was correct in issuing the declaratory order which protected substantive equality and demonstrates that Zimbabwe is not a lawless country. 4.2 Fostering substantial equality through reasonable accommodation measures According to the CRPD, ‘reasonable accommodation’ means “necessary and appropriate modification and adjustments not imposing a disproportionate or undue burden, where needed in a particular case, to ensure to persons with disabilities the enjoyment or exercise on an equal basis with others of all human rights and fundamental freedoms.”40 In other words, adopting reasonable accommodation measures suggests the adoption of reasonable adjustment measures to secure the inclusion of PWDs. In this context, for the measure to be reasonable, it should not cause undue or disproportionate burden or hardship or unjustified costs. Reasonable accommodation is essential to advance substantial equality because as noted by Marumoagae, “equality for persons with disabilities cannot stop with injunctions to refrain from invidious discrimination, but there must be a practical acknowledgment that persons with disabilities are not fully catered for by existing societal structures and that they have a right to participate fully in society and the labour market in particular”.41 39 President of the Republic of South Africa and Another v Hugo 1997 (4) SA 1 (CC); 1997 (6) BCLR 708 (CC) 40 CRPD, Article 2. 41 MC Marumoagae ‘Disability discrimination and the right of disabled persons to access the labour market’ in PER Volume 15 (1), 2012 pp.345-428 at 347; also Day, Shelagh, and Gwen Brodsky. ‘The Duty to Accommodate: Who Will