Zimbabwe Rule of Law Journal |107 • Improve independence and mobility of persons with disabilities; • Guarantee participation and supported decision-making by persons with disabilities; • Provide access and participation to quality education and work. In sum, under international law employers are compelled to adopt reasonable accommodation measures to ensure the substantial equality of PWDs. In Zimbabwe, the National Disability Board is mandated to issue adjustment orders needed for the full inclusion of PWDs in the public services; and to formulate and develop measures and policies to secure equal opportunities for PWDs in the education and employment sector.54 Nevertheless, a person served with an adjustment order has thirty days of the service of the order to appeal to the Administrative Court if the order is unreasonable or imposes undue burden on the appellant.55 This is the formulation of reasonable accommodation in Zimbabwe, where failure to comply with the adjustment order is penalised by a fine.56 Manatsa observes that the criminalisation of non-compliance with an adjustment order is “a bold step” in an attempt to ensure full accessibility and services to PWDs.57 However, the Zimbabwe National League of the Blind case showed how a recruitment Directive was discriminatory of visually impaired persons and the National Disability Board had not intervened. Nonetheless, the court was firm in ordering the respondents to “put in place mechanisms and facilities within a reasonable time that will enable the full participation of persons with disabilities, particularly those with visual impairments, and enumerators and supervisors in the conduct of future population censuses or any other such exercise”.58 This was indeed a call for the adoption of reasonable accommodation measures by the respondents in future recruitments processes. Moreover, the court did not consider whether the adjustment to 54 Disabled Persons Act, of 2001, section 5. 55 Disabled people Act of 2001, section 6 (5). 56 As above, section 6(8). 57 Proceed Manatsa “Are disability laws in Zimbabwe compatible with the provisions of the United Nations Convention on the Rights of Persons with Disabilities (CRPD)?” International Journal of Humanities and Social Science Invention Volume 4 Issue 4 (2015) 28. 58 Ibid, para 2.