section 86.5 However, in addition, there is an internal limitation in section 76, which is the progressive realisation of the right of health care, “within the limits of the resources available”. When it comes to children, section 81(1)(f) of the Constitution captures the right to health care for children in the following terms: “81. Rights of children 1. Every child, that is to say, every boy and girl under the age of eighteen years, has the right… f. to education, health care services, nutrition and shelter; … 2. A child's best interests are paramount in every matter concerning the child. ...” The “right to health care services” captured in that provision is broad and does, of course, encompass sexual and reproductive health. A key notable distinction between section 81(1)(f) and section 76 is that unlike the latter, section 81(1)(f) has no internal limitation. This means this right is not qualified by resource constraints, or anything, outside a 5 The limitation of rights in Zimbabwe works as follows: “86. Limitation of rights and freedoms 1. 2. 3. The fundamental rights and freedoms set out in this Chapter must be exercised reasonably and with due regard for the rights and freedoms of other persons. The fundamental rights and freedoms set out in this Chapter may be limited only in terms of a law of general application and to the extent that the limitation is fair, reasonable, necessary and justifiable in a democratic society based on openness, justice, human dignity, equality and freedom, taking into account all relevant factors, including— a. the nature of the right or freedom concerned; b. the purpose of the limitation, in particular whether it is necessary in the interests of defence, public safety, public order, public morality, public health, regional or town planning or the general public interest; c. the nature and extent of the limitation; d. the need to ensure that the enjoyment of rights and freedoms by any person does not prejudice the rights and freedoms of others; e. the relationship between the limitation and its purpose, in particular whether it imposes greater restrictions on the right or freedom concerned than are necessary to achieve its purpose; and f. whether there are any less restrictive means of achieving the purpose of the limitation. No law may limit the following rights enshrined in this Chapter, and no person may violate thema. the right to life, except to the extent specified in section 48; b. the right to human dignity; c. the right not to be tortured or subjected to cruel, inhuman or degrading treatment or punishment; d. the right not to be placed in slavery or servitude; e. the right to a fair trial; f. the right to obtain an order of habeas corpus as provided in section 50(7)(a).” 12