Chief Justice and every other Constitutional Judge is in the privileged and rear position of being the founding interpreters of this important document the new Constitution of Zimbabwe. B. ISSUES 3. It is submitted that there are two main issues in this particular matter on the merits. The first is clearly, the question of protection of children's rights as defined in Article 81 of the Constitution and determining whether or not early marriages and the laws allowing and permitting the same are consistence with that right. 4. In dealing with the rights of children as defined 1n the Court, this Honourable Court must take into account the fact that the Court itself is the guardian of all minors in Zimbabwe. 5. Put in simple terms, this is not a matter in which this Court is neutral. It cannot be. It is duty bound by law to act in the best interest of minor children and in this regard, the Court in very simple terms is being asked to declare that it surely cannot be in the interest of minor children that they get married before the age of 18 years. 6. The second main issue that the Court will have to consider is the issue of discrimination between men and women. In particular the discrimination imposed by Section 22 of the Marriages Act [Chapter 5: 11] vis-a-vis the differentiation between dates of marriage for men and women. 7. The inquiry under this head, will entail a look at the doctrine of equality within the context of Section 56 of the Constitution of Zimbabwe. Page 2 of 46 Applicant's Heads of Argument in the matter between: Lovencss Mudzuru & Another v Minister of Justice Legal & Parliamentary Affairs & 2 Others Case Number CCZ 79/2014 Prepared byTendai Biti Law