The Zimbabwe government has no legislation which regularizes the situation of those living in the “illegal” sector.153 The result is that few people in Zimbabwe—especially those living in informal houses in urban high density areas—have legal security of tenure. But, Zimbabwe has an obligation to respect the right to housing, not only in the case of those who can show documents to prove legal title, but also to those living on informal settlements. Both the Committee on Economic Social and Cultural Rights and the UN Commission on Human Rights154 have called on states to provide legal tenure to those threatened with forced eviction. In its General Comment 4, paragraph 8, the ICESCR lists various types of tenure, including informal settlements, and adds: “[n]otwithstanding the type of tenure, all persons should possess a degree of security of tenure which guarantees legal protection against forced eviction, harassment and other threats. States parties should consequently take immediate measures aimed at conferring legal security of tenure upon those persons and households currently lacking such protection, in genuine consultation with the affected persons and groups.”155 General Comment 7 of the ICESCR on forced evictions calls for legislative measures which “(a) provide the greatest possible security of tenure to occupiers of houses and land, (b)conform to the Covenant and (c) are designed to control strictly to the circumstances under which evictions may be carried out.”156 Due process and the right to effective remedy The CESCR holds that the right to adequate housing is at least consistent with the provision of legal remedies such as legal appeals aimed at preventing planned evictions or demolitions through the issuance of court-ordered injunctions and legal procedures seeking compensation following an illegal eviction.157 153 Zimbabwe State Party Report on the implementation of the International Covenant on Economic, Social and Cultural Rights, 25 September 1995. 154 See Commission on Human Rights resolution 1993/77a on forced evictions. 155 CESCR, General Comment 4, para 8. 156 CESCR, General Comment 7. 157 CESCR, General Comment 4, para 17. See also the UN Special Rapporteur on adequate housing as a component of the right to an adequate standard of living, who in paragraph 46 (c) of his 2002 report to the Commission on Human Rights, called on governments to “[g]uarantee access to judicial remedies for violations of the right, such as forced evictions, deliberate denial of civic services, including reparations for damages suffered…” 39