48 In Their Capacity as Human Rights Defenders: Women Chapter 5 Towards a Conducive Environment for Women HRDs 5.1 Why the need to create an enabling environment? Several resolutions have been adopted by the United Nations and within the African human rights system to strengthen the protection of HRDs. In spite of such efforts at the international and continental level, women HRDs in Zimbabwe have continued to be on the receiving end of abuse and violations. Over the years, as highlighted in the cases presented in this publication, ZLHR has intervened through litigation and other activities and has documented information on the experiences of, and challenges facing, women HRDs. The nature of their interaction with state institutions – particularly from primary sources such as legal records, affidavits and court process collected and utilised by lawyers representing the women HRDs – provides a clear evidence base of the level of abuse and tactics to which women HRDs are exposed. These challenges can begin to be addressed when state actors become willing to comply with their obligations and where there is transformation in attitudes, policies and practices of state institutions. Improved protection will also depend on law reform as well as the will of society to embrace such changes in both private and public spheres. There has been some movement by some governments from around the world (including Latin America and some Asian countries) to give effect to the rights of HRDs. In such progressive countries a number of laws, policies and institutions have either been transformed, or created where they did not exist, as protection of HRDs begins to be taken more seriously. These reforms have been influenced by the United Nations as set out in Article 12 of the Declaration on HRDs, which guarantees the right of everyone, individually and in association with others, to participate in peaceful activities against violations of human rights and fundamental freedoms. Governments are also obliged to take all necessary measures to ensure the protection by the competent authorities of everyone, individually and in association with others, against any violence, threats, retaliation, de facto or de jure adverse discrimination, pressure or any other arbitrary action as a consequence of their legitimate exercise of the rights referred to in the UN Declaration on HRDs. This obligation means that everyone is entitled, individually and in association with others, to be protected effectively under national law in reacting against or opposing, through peaceful means, activities and acts, including those by omission, attributable to states that result in violations of human rights and fundamental freedoms, as well as acts of violence perpetrated by groups or individuals that affect the enjoyment of human rights. Of particular interest to women HRDs is UN General Assembly Resolution 68/181 of 18 December 2013 - Promotion of the Declaration on the Right and Responsibility of Individuals, Groups and Organs of Society to Promote and Protect Universally Recognized Human Rights and Fundamental Freedoms: protecting women human rights defenders. This resolution calls on UN member states to take appropriate, robust and practical steps to protect women HRDs. It also