departments, of their duty to uphold the Constitution, by ensuring that their conduct is not only lawful, it must be procedurally fair. Under no circumstances are government departments at liberty to unilaterally and arbitrarily demolish any structures in the absence of a court order authorizing them to do so, whether the structures were built without approval of building plans, or layout plans or without complying with any other legal requirement. Even if the structures are an eyesore, they cannot just be razed to the ground at the drop of a hat, or on a whim.” 6.3 Right to Freedom of Movement 6.3.1 The investigation also revealed that the right to freedom of movement and residence of the complainants has been heavily curtailed. Section 66 (2) (a) of the Constitution of Zimbabwe provides for the right of every citizen of Zimbabwe to move freely within Zimbabwe. It was noted that the boom gates which have been erected at entry points into Arnold Farm hinder the free movement of people from and into the farm as they are manned by purported ZRP officers day and night. Such measures which impact negatively on a right given by the Constitution are unconstitutional. 6.3.2 Resolution 231 of the African Commission on Human and Peoples Rights3 states that State Parties must, before resorting to eviction ensure availability of alternatives, ensure that legal procedures are complied with, take concrete measures to ensure security of tenure, and that alternative housing complies with international and regional standards on the right to adequate housing. Notwithstanding 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. This is absent in the context of the residents of Arnold Farm who for almost 17 years since their settlement in 2000 have been subjected to a series of evictions and live in uncertainty. 3 Resolution 231 of the African Commission on Human and Peoples’ rights on the right to adequate housing and protection from forced evictions www. http://www.achpr.org/sessions/52nd/resolutions/231/ Page 10 of 22