Zimbabwe Rule of Law Journal |105 take positive action to ensure that members of disadvantaged groups benefit equally from services offered to the general public is subject to the principle of reasonable accommodation”.45 On the employment terrain, reasonable accommodation boils down to “any change in the work environment or in the way things are customarily done that enables an individual with a disability to enjoy equal employment opportunities’’.46 According to the Americans with Disabilities Act of 1990, there are three types of “reasonable accommodations” at the work place: “(i) modifications or adjustments to a job application process that enable a qualified applicant with a disability to be considered for the position such qualified applicant desires; or (ii) modifications or adjustments to the work environment, or to the manner or circumstances under which the position held or desired is customarily performed, that enable a qualified individual with a disability to perform the essential functions of that position; or (iii) modifications or adjustments that enable a covered entity’s employee with a disability to enjoy equal benefits and privileges of employment as are enjoyed by its other similarly situated employees without disabilities”.47 However, as indicated earlier, ‘reasonable accommodation’ should not cause “undue hardship” to the employer. This was clarified through the US case of Norcross v Sneed where the complainant, who 48 was blind, had his application to work as school librarian rejected on the ground that once a year the librarian would have to take learners on a field trip. The court was of the view that possessing a driving license for the position was neither reasonable nor essential. Driving ability was necessary for the job for it was required only once a year. Alternative transport could be arranged by the employer without suffering undue hardship or burden. 45 As above, para 79. 46 Title I of the Americans with Disabilities Act of 1990 (the ‘ADA’). 47 Enforcement Guidance: Reasonable Accommodation and Undue Hardship under the Americans with Disabilities Act available at http://www.eeoc.gov/policy/docs/accommodation.html (accessed on 21 September 2016). 48 Norcross v Sneed 755 F2d 113 (8th Cir 1983)