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Community Working Group on Health and Nyasha Batitsa v Minister of Health and Child Welfare and 3 Others

High Court of Zimbabwe, Harare11 November 2025
HH-622-25HH-622-252025
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1



                                                           HH-622-25

                                                           HCH 931/25



COMMUNITY WORKING GROUP ON HEALTH

And

NYASHA BATITSA

Versus

MINISTER OF HEALTH AND CHILD WELFARE

And

MINISTER OF JUSTICE, LEGAL AND PARLIAMENTARY AFFAIRS

And

THE ATTORNEY-GENERAL OF ZIMBABWE

And

PARLIAMENT OF THE REPUBLIC OF ZIMBABWE



HIGH COURT OF ZIMBABWE

CHIRAWU-MUGOMBA J

Harare, 12 September, 7 and 8, 13 October, 10 and 11 November 2025

T. BITI, for the applicants

J. SHUMBA for the 1st -3rd respondents

S. HOKO, for the 4th respondent



COURT APPLICATION



CHIRAWU-MUGOMBA J

INTRODUCTION

         This is a constitutional application challenging the validity of s 4(a) of the

Termination of Pregnancy Act [Chapter 15:10] (hereinafter referred to as ‘the
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Act’) and the definition of unlawful intercourse in s 2(1) of the Act. This

application is made in terms of s85(1)(d) of the Constitution of Zimbabwe, 2013

(hereinafter referred to as the ‘Constitution’).

The order sought is as follows.

   1. That section 4(a) of the Termination of Pregnancy Act [Chapter 15:10] be and is

       hereby declared ultra vires the provisions of section 48(1), 51, 53, 78(1) of the

       Constitution of Zimbabwe.

   2. That section 4(a) of the Termination of Pregnancy Act be and is hereby declared

       constitutionally invalid.

   3. That the definition of ‘unlawful intercourse’ in section 2(1) of the Termination of

       Pregnancy Act [Chapter 15:10] be and is hereby declared to be a breach of

       section 48(1, 51, 76 and 56 (1) of the Constitution.

   4. That the definition of ‘unlawful intercourse’ in section 2(1) of the Termination of

       Pregnancy Act be and is hereby declared to be constitutionally invalid.

   5. The above declarations of constitutional invalidity are suspended until such time
       as the Constitutional Court has confirmed the same in terms of section 167(3) of

       the Constitution of Zimbabwe.

   6. The above order of constitutional invalidity is referred to the Constitutional

       Court for confirmation in terms of section 175 (1) of the Constitution.

   7. There is no order as to costs.

THE APPLICATION

Background facts

       The founding affidavit of first respondent is deposed to by one Itai Rusike in his

capacity as the Executive Director of the applicant. He makes the following averments.

The first applicant in this matter is a universitas at law duly registered by a constitution

with the capacity to sue and be sued, whose mandate focuses on attainment and
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actualisation of human rights and equitable health service in Zimbabwe. The second

applicant is a gender -based human rights activist and a member of Parliament. The

first respondent is the Minister of Health and Child Care, who is responsible for

promoting the health and quality of life of Zimbabweans. He is also responsible for

administering the Act. The second respondent is the Minister responsible for providing

and securing and effecting justice delivery, and his responsibilities include

investigating and prosecuting crimes, including violations of the Act and s 60 of the

Criminal Law Codification and Reform Act [Chapter 9:23] (hereinafter referred to as “the

Code”). The third respondent is the Attorney General of Zimbabwe, and she is in charge

inter alia of representing the government of Zimbabwe in all legal and constitutional

matters. The fourth respondent is the Parliament of the Republic of Zimbabwe, the

country’s sole legislative body. It has no direct interest in this matter, but it has only

been cited because the constitutionality of a law is at stake.

         The applicants submit that, in 1977, the Act was passed by the Parliament of

Rhodesia, and it was last amended by the Code, which was initially promulgated in

2004 and amended in 2018. Section 60 of the Code criminalises performing an abortion

outside of the perimeters prescribed in the Act. They submit that s 60 of the Code

further provides that performing or receiving an illegal abortion carries a penalty of up

to five years imprisonment and a fine of up to US$700.00. It is the applicants’

submission that this penalty is one of the harshest penalties for abortion in the world.

The applicants contend that the Act prohibits abortion in Zimbabwe except under a

narrow set of circumstances. The applicants submit that the Act allows abortion only: -

   1. Where the continued pregnancy endangers the life of the woman concerned or

       so constitutes a serious threat and permanent impairment of her physical

       health that the termination of the pregnancy is necessary to ensure her life or

       physical health.

   2. Where there is a serious risk that the child to be born will suffer from a physical

       or mental defect of such a nature that he will be permanently seriously

       handicapped.
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   3. Where there is a reasonable possibility that the foetus is conceived as a result of

       unlawful intercourse.

         The applicants contend that the above circumstances, as stipulated in the Act,

exclude mental health conditions as a basis for obtaining legal abortion. They further

argue that excluding mental health is unlawful and unconstitutional, as it disregards

the genuine challenges women experience with mental health, including those that

may arise after childbirth. The applicants aver that the legislature’s intention to exclude

mental health from s 4(a) in so far as it relates to the health of the mother was

intentional. It is the applicants’ submission that the law also ought to have allowed

legal abortion where there is a serious risk that the mother suffers from a mental

defect, is mentally handicapped, or would be mentally handicapped or challenged after

giving birth. The applicants contend that this exclusion affects the right to human

dignity of the mother concerned and the right to health of the mothers concerned,

which is codified in s 75 of the Constitution. The applicants submit that mentally ill

patients cannot consent to sexual intercourse, and it follows that any mentally ill

patient must have the right to legal abortion.

     They state that s 64(3) of the Code criminalises various forms of sexual activities

with a mentally incompetent person and the charge is rape, indecent of aggravated

indecent assault. The applicants argue that s 106 of the Mental Health Act [ Chapter

15:12] makes it an offence for anyone working in a mental health institution, or having

custody of a mental patient, to engage in sexual intercourse with that patient though

the offence created is not equivalent to rape. However, the definition of unlawful

intercourse in the Act in s2(1) excludes unlawful intercourse as envisaged in s106. This

is a violation of s 48(1), 50, 56(1) and 76 of the Constitution. To show the gravity of the

problem of abortion and its aftereffects, the applicants attach a report titled, ‘National

Assessment on adolescent pregnancies in Zimbabwe’, June 2023, commissioned by UN

Agencies and the government of Zimbabwe.

The applicants locate the application under two broad frameworks as follows: -


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   a. That s4(a) of the Act infringes the right of mentally challenged women to safe

       and lawful abortion in breach of the rights codified under s48(1), 51, 53, 56(1)

       and 78 of the Constitution.

   b. S2(1) of the Act in its definition of unlawful intercourse is in breach of the

       Constitution in that it excludes intercourse proscribed by s106 of the Mental

       Health Act [ Chapter 15:12].




The opposition

         The first respondent opposes the application through the person of one

Wenceslas Nyamayaro, the acting Secretary in the Ministry. He submits that section

4(a) does not unlawfully and unconstitutionally discriminate and leave out mental

health patients. Severe mental health conditions that threaten a mother’s life are

already covered under the common provision relating to serious threat of permanent

impairment of physical health. Allowing abortion on mental health concerns may lead

to misuse or misinterpretation. Determining mental health threats is subjective, unlike

physical health threats. Mental health concerns can be expanded through broader

psychological and psychiatric support instead of broadening abortion laws.

       Additionally, it is dangerous to assume tha t every woman facing mental health

challenges cannot carry a baby to full term.

In his opposing affidavit, the second respondent raised a preliminary objection on the

applicants’ locus standi and that the applicants had not exhausted other available

remedies. Further that the second applicant in identifying as a member of Parliament

and human rights activist, could utilize the avenue of lobbying for the amendment of

the law. Also, that the doctrine of constitutional avoidance and separation of powers is

clear. At the hearing, counsel for the first to third respondents abandoned expressly

the issue of locus standi and implored the court to deal with the merits. It is assumed

that all the other preliminary issues raised were also abandoned. On the merits, the

second respondent avers that while grounds many exist for widening the grounds
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upon which pregnancy may be terminated, it is not the duty of courts to do so as this is

tantamount to usurping the functions of the legislature. While the applicants may

have identified gaps, it is the legislature that must deal with them. This would be

predicated on wide consultations.

     The third respondent submits that her mandate is defined in section 114 of the

Constitution and there was no need for her citation in the matter.

   The fourth respondent’s stance is that it will abide by the decision of the court.

Answering affidavits

      Nothing significant turns on the answering affidavits.

SUBMISSIONS AND HEADS OF ARGUMENT

          The first to the third respondents having abandoned the preliminary issues,

there is no need to deal with the heads in respect of these.

Applicants

The applicants implore the court to take a purposive approach that recognises the

right to life. See Mudzuru and anor vs. Ministry of Justice and ors, 2015(2) ZLR 31(S) and,

Chihava and ors vs Principal Magistrate and anor, 2016 (2) ZLR 196 (CCZ). They submit

that the method of establishing invalidity is well set. The first is to determine whether

the provision takes away rights and causes infraction on rights and once this is

established, the second rung is whether the provision is saved by section 86(2) of the

constitution.    See Chitungwiza Residents Trust vs Minister of Justice, legal and

Parliamentary Affairs and ors, CCZ 3/22. Section 4(a) of the act infringes section 48(1) of

the Constitution that bestows the right to life. The right to health is recognised in a

plethora of international instruments such as the definition by the WHO, UDHR and the

ICESCR.

             Section 4(a) excludes the rights of a mother in relation to mental health.

Section 56 (a) of the Constitution is about equality before the law. There is no provision


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in any act of Parliament that creates differential treatment for women and men, yet

section 4(a) of the Act does.

          Further, that, the constitutional right threshold has been set in a number of

cases – see Chimakure and ors vs. AG, (2013) (2) ZLR 466 (S). The approach adopted pre

2013 constitution in cases such as In Re Munhumeso and ors, 1994(1) ZLR 49(S) and

Nyambirai vs NSSA, 1995(2) ZLR 1(S) is still valid post 2013. This is premised on a high

threshold justifying limitations to a right. The standard set by the court is as adopted

from the Canadian case of R vs Oakes, 1996(1) SCR 103 as follows. (1) Whether the

limitation serves a legitimate purpose which is sufficiently important in a free

democratic country (2) whether the limitation is rationally connected to the said

objective (3) whether the limitation impairs the right as little as possible and (4)

whether the actual benefits of the limitation are proportionate to its meritorious

consequences for the right order. Section 86(2) of the constitution sets out the

sequential logic of the analysis of the rights concerned.

First to third respondents

The respondents submit that every law is presumed to be constitutionally valid until it

is set aside including a law that is being challenged as in casu. The court must be

satisfied that the order sought represents a correct interpretation of the law- S v

Chakumba, CCZ-10-19 and Mupungu v Minister of Justice, legal and Parliamentary Affairs

and ors, CCZ-7-21. The issue of constitutional invalidity does not arise in this matter.

What remains is for Parliament to amend the impugned provisions of the Act to

address the gaps properly identified.

Observations

Before dealing with the legal issues for determination, it will be remiss of me not to

comment on the nature and presentation of the application. In my view, while the

issues at hand can be determined, the presentation of the applicants’ case could have

been done better. It criss -crosses from one point to the next in a sometimes-

incoherent manner.

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ISSUES FOR DETERMINATION

It is imperative that I set out the relevant legal provisions in the Act on definition of

unlawful intercourse and circumstances under which pregnancy can be terminated as

follows: -

“unlawful intercourse” means rape, other than rape within a marriage, and sexual intercourse within a
prohibited degree of relationship, other than sexual intercourse with a person referred to in paragraph (i)
or (j) of subsection (1) of section 75 of the Criminal Code.

    4.   Circumstances in which pregnancy may be terminated

Subject to this Act, a pregnancy may be terminated—(a)where the continuation of the pregnancy so
endangers the life of the woman concerned or so constitutes a serious threat of permanent impairment of
her physical health that the termination of the pregnancy is necessary to ensure her life or physical health,
as the case may be; or

On the other hand, section 106 of the Mental Health Act states:

         “106. Unlawful sexual intercourse with patients

         (1) Subject to this section, any person who—

         (a)     being employed in or at an institution, special institution or other place where a patient is
                 detained or receiving treatment in terms of this Act, has sexual intercourse with the
                 patient; or

         (b)     having the custody, care or charge of any patient in terms of this Act, has sexual
                 intercourse with the patient;

                 shall be guilty of an offence and liable to a fine not exceeding level seven or to
                 imprisonment for a period not exceeding five years or to both such fine and such
                 imprisonment.

         (2)     For the purposes of subs (1), a patient shall be deemed to be detained in an institution,
                 special institution or other place or to be in custody, care or charge, even though he may
                 have escaped therefrom or be absent therefrom with or without leave, until he is duly
                 discharged or ceases to be in such custody, care or charge in terms of this Act.

         (3)     It shall be a defence to a charge under subs (1) for the accused person to prove that,
                 when the alleged offence was committed—

         (a)     he was the spouse of the patient concerned; or

         (b)     he did not know and had no reason to believe or suspect that the patient concerned was
                 detained or receiving treatment in the institution, special institution or place concerned
                 or that the patient was in his custody, care or charge, as the case may be.

         (4)     The consent of the patient concerned shall not be a defence to a charge under subs (1).”

The Mental Health Act defines a patient as follows,
“patient” means a person—(a)who is mentally disordered or intellectually handicapped; or(b)concerning
whom proceedings under this Act are considered necessary to determine whether or not he is mentally
disordered or intellectually handicapped;

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               In terms of s 171 of the Constitution, the High Court has jurisdiction to

adjudicate on constitutional matters, except in cases where exclusive jurisdiction is

reserved for the Constitutional Court. Section 171 states that:

       “(1) The High Court—

       (a) has original jurisdiction over all civil and criminal matters throughout Zimbabwe;

       (b) has jurisdiction to supervise magistrates courts and other subordinate courts and to review
       their decisions;

       (c) may decide constitutional matters except those that only the Constitutional Court may decide; and

       (d) has such appellate jurisdiction as may be conferred on it by an Act of Parliament.” (emphasis
       added)

                  This provision underscores the centrality of the High Court as a court of

first instance, with wide jurisdiction over both ordinary and constitutional matters,

subject only to the limits imposed by the Constitution itself. Litigants may approach the

High Court through a court application in terms of r 107 of the High Court Rules, 2021.

The High Court’s jurisdiction and power to deal with applications for constitutional

invalidity were authoritatively affirmed in Combined Harare Residents’ Association & Ors v

The Minister of Local Government, Public Works and National Housing CCZ-3-24 at pg. 13:

       “As stated above, it is my finding that the High Court ordinarily has jurisdiction to make an order
       of constitutional invalidity of any law, practice, custom, or conduct. The applicable cause of action
       in such matter among others is the principle of legality and in particular the ultra vires doctrine.”

     Thus, the jurisdiction conferred upon the High Court by s 171 of the Constitution,

coupled with the procedural framework under the High Court Rules, positions it as a

vital forum for the protection and enforcement of constitutional rights.

Given the above jurisdiction of the High Court, in my view the legal issues for

determination are as follows: -

   1. Whether or not s 4(a) of the Act infringes the right of mentally challenged

       women to safe abortion in breach of the rights codified in s48, 51, 53, 78 and

       56(1) of the Constitution?

   2. Whether or not s2(1) of the Act in its definition of unlawful intercourse is in

       breach of s48, 51, 56(1) of the Constitution in that it excludes lawful abortion

       from sexual intercourse proscribed by s106 of the Mental Health Act?

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   3. The appropriate remedy?


APPLICATION OF LAW TO THE FACTS


Whether or not s 4(a) of the Act infringes the right of mentally challenged women

to safe abortion in breach of the rights codified in s48, 51, 53, and 56(1) of the

Constitution?


     It is the applicant’s contention that s 4(a) of the Act infringes the right of mentally

ill women to safe and lawful abortion in breach of their rights codified by ss 48(1), 52,

53 and 56(1) of the Constitution. The applicants submit that s 4(a) of the Act is an

infringement of the right to life, right to health and the right to human dignity.

Contrastingly, the first and second respondents submit that s 4(a) does not unlawfully

and unconstitutionally discriminate and leave out mental health patients. It is their

contention that severe mental health conditions that threaten a mother’s life are

already covered under the provision and medical professionals can assess whether a

mental health condition has such a severe impact that it necessitates abortion under

the current law. Moreover, they submit that mental health concerns can be addressed

through expanded access to psychological and psychiatric support instead of

broadening abortion laws.        The applicants have pleaded what is called under

constitutional law, the principle of disparate impact.          A glance at comparative

jurisdiction will illustrate this constitutional principle. It speaks to a seemingly neutral

law, but one that has a different impact on different groups.

     In South Africa, the Constitutional Court recognised indirect discrimination in City

Council of Pretoria v Walker 1998 (2) SA 363. The case involved different billing and debt

collection systems for historically white suburbs and black townships. Although the

policy was facially neutral, its practical effect corresponded to racial divisions, with

white residents facing stricter debt enforcement and higher charges. The Court held

that this differential impact along racial lines amounted to unfair discrimination

because it reinforced historic inequalities and burdened individuals arbitrarily. The


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Constitutional Court of South Africa, on pg. 22 - 24 para 28 - 32 of the judgment held

that:

             “The four judgments of this Court to which I have referred 24 were all delivered after the
             judgment of the High Court in this case. They deal extensively with the equality provision
             in the interim Constitution and analyse the concept of discrimination.
             [29] In Harksen we held that the enquiry as to whether differentiation amounts to unfair
             discrimination is a two-stage one.

             (a) Firstly, does the differentiation amount to discrimination? If it is on a specified
             ground, then discrimination will have been established. If it is not on a specified ground,
             then whether or not there is discrimination will depend upon whether, objectively, the
             ground is based on attributes and characteristics which have the potential to impair the
             fundamental human dignity of persons as human beings or to affect them adversely in a
             comparably serious manner.

             (b) (ii) If the differentiation amounts to discrimination, does it amount to unfair
             discrimination? If it has been found to have been on a specified ground, then unfairness
             will be presumed. If on an unspecified ground, unfairness will have to be established by
             the complainant.

             The test of unfairness focuses primarily on the impact of the discrimination on the
             complainant and others in his or her situation.

             [30] Section 8(2) prohibits unfair discrimination which takes place (a) directly or indirectly.
             This is the first occasion on which this Court has had to consider the difference between
             direct and indirect discrimination and whether such difference has any bearing on the
             section 8 analysis as developed in the four judgments to which I have referred.

             [31] The inclusion of both direct and indirect discrimination within the ambit of the
             prohibition imposed by section 8(2) evinces a concern for the consequences rather than
             the form of conduct. It recognises that conduct which may appear to be neutral and non-
             discriminatory may nonetheless result in discrimination, and if it does, that it falls within
             the purview of section 8(2).

             [32] The emphasis which this Court has placed on the impact of discrimination in deciding
             whether or not section 8(2) has been infringed is consistent with this concern. It is not
             necessary in the present case to formulate a precise definition of indirect discrimination.
             The conduct of which the respondent complains is summarised in paragraph 6 of this
             judgment. It is sufficient for the purposes of this judgment to say that this conduct which
             differentiated between treatment of residents of townships which were historically black
             areas and whose residents are still overwhelmingly black, and residents in municipalities
             which were historically white areas and whose residents are still overwhelmingly white
             constituted indirect discrimination on the grounds of race.” (underlining for emphasis)

           The Court found that although the policy was not explicitly race-based and

was more geographical, in practice the differential treatment aligned with racial

divisions as residents of the black townships were paying a flat lower rate and were

given leniency on arrears, while white residents bore higher costs and strict

enforcement. This constituted indirect discrimination based on race, since the policy’s

effect was to favour one racial group over another. This case underscored that a law

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may be unconstitutional if its implementation indirectly entrenches disadvantage, even

without express racial classifications.

    In Canada, equality jurisprudence under s 15 of the Canadian Charter of Rights and

Freedoms similarly emphasises the effects of a law over its form. In Andrews v Law

Society of British Columbia [1989] 1 SCR 143, the Supreme Court held that equality is

breached when a law imposes burdens or denies benefits based on irrelevant personal

characteristics, regardless of intent. Per Dickson C.J. and McIntyre, Lamer, Wilson and

L'Heureux-Dubé JJ, at p. 3, the court held:

              “Section 15(1) of the Charter provides for every individual a guarantee of

              equality before and under the law, as well as the equal protection and equal
              benefit of the law without discrimination...

              …The words "without discrimination" in s. 15 are crucial. Discrimination is a distinction

              which, whether intentional or not but based on grounds relating to personal

              characteristics of the individual or group, has an effect which imposes disadvantages not

              imposed upon others or which withholds or limits access to advantages available to other

              members of society. Distinctions based on personal characteristics attributed to an

              individual solely on the basis of association with a group will rarely escape the charge of

              discrimination, while those based on an individual's merits and capacities will rarely be so

              classed.”



          In, Eldridge v British Columbia (Attorney General), [1997] 3 SCR 624, the

Constitutional Court found that failure to provide sign-language interpreters in

hospitals excluded deaf patients from effective access to healthcare, amounting to

unconstitutional discrimination by omission. It held as follows,
              “The only question in this case is whether the appellants have been afforded “equal
              benefit of the law without discrimination” within the meaning of s. 15(1) of the Charter.
              On its face, the medicare system applies equally to the deaf and hearing populations.
              The appellants’ claim, nevertheless, is one of “adverse effects” discrimination, protection
              against which is provided by s. 15(1) of the Charter. A discriminatory purpose or intention
              is not a necessary condition of a s. 15(1) violation. A legal distinction need not be
              motivated by a desire to disadvantage an individual or group in order to violate s. 15(1).
              It is sufficient if the effect of the legislation is to deny someone the equal protection or
              benefit of the law. Adverse effects discrimination is especially relevant in the case of
              disability. In the present case the adverse effects suffered by deaf persons stem not from
              the imposition of a burden not faced by the mainstream population, but rather from a
              failure to ensure that deaf persons benefit equally from a service offered to everyone.”




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       Most recently, in Fraser v Canada (Attorney General) [2020] 3 SCR 113, a rule on

pensionable service credits disproportionately disadvantaged women who opted for

job-sharing.     The    Court     reaffirmed      that     adverse      impact      discrimination       is

unconstitutional, holding that “effects, not just purposes,” determine equality

violations. Under the Charter’s limitations clause, the state bears the burden of

justifying such an impact, a principle mirrored in s 86 of Zimbabwe’s Constitution.

   In contrast, in the United States, constitutional equal protection claims generally

require proof of discriminatory intent. In Washington v Davis, 426 U.S. 229 (1976), a

neutral police recruitment test that excluded a higher percentage of black applicants

was upheld because there was no evidence of intentional racial bias. The Supreme

Court in this case held that:

       “The central purpose of the Equal Protection Clause of the Fourteenth Amendment is the
       prevention of official conduct discriminating on the basis of race. It is also true that the Due
       Process Clause of the Fifth Amendment contains an equal protection component prohibiting the
       United States from invidiously discriminating between individuals or groups. Bolling v. Sharpe,
       347 U. S. 497 (1954). But our cases have not embraced the proposition that a law or other official
       act, without regard to whether it reflects a racially discriminatory purpose, is unconstitutional
       solely because it has a racially disproportionate impact.

       Almost 100 years ago, Strauder v. West Virginia, 100 U. S. 303 (1880), established that the
       exclusion of Negroes from grand and petit juries in criminal proceedings violated the Equal
       Protection Clause, but the fact that a particular jury or a series of juries does not statistically
       reflect the racial composition of the community does not, in itself, make out an invidious
       discrimination forbidden by the Clause.

       A purpose to discriminate must be present which may be proven by systematic exclusion of
       eligible jurymen of the proscribed race or by unequal application of the law to such an extent as to
       show intentional discrimination.”

    Thus, under United States constitutional law, a disparate impact alone does not

establish a violation. However, United States statutory law, through measures such as

the Civil Rights Act 1964 and the Fair Housing Act, does recognise disparate impact

discrimination. Likewise, in Griggs v Duke Power Co. 401 US 424 (1971) and Texas Dept. of

Housing v Inclusive Communities Project 576 US 519 (2015), the burden was shifted to

employers or institutions to justify neutral practices that disproportionately affect

protected groups.

               In the United Kingdom, the Equality Act 2010 explicitly prohibits indirect

discrimination, defining it as a neutral provision, criterion, or practice that places a

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protected group at a particular disadvantage unless objectively justified. For example, a

full-time work requirement may indirectly discriminate against women who need

flexible hours for caregiving.

        At the European level, the European Court of Human Rights (ECHR) in D.H. & Ors

v Czech Republic [GC] (Application No. 57325/00) 2007, recognized that policies

producing disproportionate adverse effects on particular groups can violate Article 14

of the European Human Rights Convention (non-discrimination) taken together with

Article 2 of Protocol No. 1. The Court found that the practice of placing Roma children

in “special schools” based on neutral testing criteria was indirectly discriminatory

because of its statistically proven disparate impact on Roma pupils and lack of objective

justification. The Court affirmed that a measure “not specifically aimed at a group” may

still be discriminatory if it produces unjustified inequality in effect.

           The preponderant view from this comparative therefore is that a law that

excludes a certain group from its benefits or protections or imposes burdens in a way

that impacts one group more than others can amount to unlawful discrimination, even

if the law is neutral on its face. The key is whether the effects of the law undermine the

guarantee of equal protection of the laws and substantive equal enjoyment of rights.

       In Chikutu & Ors v Minister of Lands, & Ors CC27/23 para 45-47, the court had
this to say,

       “[45] The Constitution is a statute. As such, it is subject to the established canons of interpretation.
       Accordingly, a court must construe the provisions of the Constitution literally to give effect to its
       ordinary meaning unless doing so would result in an absurdity. Where, however, this is not
       possible, a court is enjoined to construe the provisions in a manner that gives effect to the rights
       being protected.

       [46] As submitted by Mr. Biti, the Constitution is a product of negotiation between various
       stakeholders and thus embodies the values and aspirations of the people of Zimbabwe. It marks a
       departure from a colonial past. It has a bill of rights that is justiciable that is binding on all arms of
       the State and the citizenry at large.

       [47] With these principles in mind, the Court must then examine the constitutional provision to
       determine its meaning and interpret the challenged legislation to decide if the alleged violations
       have been established. This accords with canons of interpretation and has been emphasized time
       and time by the courts in this jurisdiction in a long line of authorities. The approach by the court
       was settled by GUBBAY CJ in In Re Munhumeso & Ors 1994(1) ZLR 49(S), at 59B-E, where the learned
       former Chief Justice said the following:




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               ‘Two general interpretational principles are to be applied. The first was lucidly expressed
               by Georges CJ in Zimbabwe Township Developers (Pvt) Ltd v Lou‘s Shoes (Pvt) Ltd 1983 (2) ZLR
               376 (S) at 382B-D; 1984 (2) SA 778 (ZS) at 783A-D, to this effect:

               ‘Clearly a litigant who asserts that an Act of Parliament or a Regulation is unconstitutional
               must show that it is. In such a case the judicial body charged with deciding that issue
               must interpret the Constitution and determine its meaning and thereafter interpret the
               challenged piece of legislation to arrive at a conclusion as to whether it falls within that
               meaning or it does not. The challenged piece of legislation may, however, be capable of
               more than one meaning. If that is the position then if one possible interpretation falls
               within the meaning of the Constitution and others do not, then the judicial body will
               presume that the law makers intended to act constitutionally and uphold the piece of
               legislation so interpreted. This is one of the senses in which a presumption of
               constitutionality can be said to arise. One does not interpret the Constitution in a
               restricted manner in order to accommodate the challenged legislation. The Constitution
               must be properly interpreted, adopting the approach accepted above. Thereafter the
               challenged legislation is examined to discover whether it can be interpreted to fit into the
               framework of the Constitution.’

    From the above case, it follows that Constitutional interpretation is not merely a

mechanical exercise, the court must give effect to the purpose and spirit of the

Constitution. The court must avoid interpretations that narrow or undermine

fundamental rights as this would weaken the transformative nature of the

Constitution. At the same time, the presumption of constitutionality requires that

legislation be upheld where possible, provided rights are not rendered meaningless.

The court must therefore balance giving full effect to the rights in the Bill of Rights with

respecting Parliament’s role in enacting laws within constitutional limits.

This assertion was well articulated in the case Buchanan & Co v Babco Ltd (C.A.) [1977]

QBC 208 at 213, as Lord Denning held that:

       “When they come upon a situation which is to their minds within the spirit-but not the letter- of
       the legislation, they solve the problem by looking at the design and purpose of legislation- at the
       effect which it was sought to achieve. They then interpret the legislation so as to achieve the
       desired effect. This means that they fill in gaps, quite unashamedly. Without hesitation. They ask
       simply, what is the sensible way of dealing with this situation so as to give effect to the presumed
       purpose of the legislation? To our eyes- shortsighted by tradition- it is legislation, pure and simple.
       But to their eyes, it is fulfilling the true role of the courts. They are giving effect to what the
       legislature intended or may be presumed to have intended.” [my emphasis]

    This framework guides the examination of s 4(a) of the Act to determine whether

excluding mental health as a ground for abortion unjustifiably limits the constitutional

rights claimed by the applicants.




                                                    15
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         The first respondent avers that s 4(a) of the Act may be interpreted to include

severe mental health conditions under the existing “life-threatening” provision. It

becomes necessary to interrogate what the term ‘life-threatening’ entails. According to

the Meriam Webster Dictionary, the term life-threatening is defined as follows:

“capable of causing death: potentially fatal”. The Advanced Learner Oxford Dictionary

(8th Ed) 2010 describes the term as “Likely to kill”.

       Considering the above definitions, mental health is incapable of causing death.

Life-threatening in these circumstances would mean health implications that may

potentially cause death to the mother during childbirth or in the continued process of

carrying the baby to term. Such an interpretation is not explicit and may leave women

with mental health challenges without clear protection. However, attention must be

drawn to the first part of s 4(a), which provides that:

       “where the continuation of the pregnancy so endangers the life of the woman concerned…”

     A pregnant woman living with a mental health condition may face serious risks if

she is not in a stable state of mind, as this could compromise her ability to maintain the

pregnancy safely or care for herself adequately. In such circumstances, continuing with

the pregnancy may endanger her life. The court, vested with the constitutional

responsibility of developing the law in the interests of justice, could interpret the

relevant provision to encompass mental health. I am mindful of the dynamics of such

an approach.     Such a wide interpretation may carry inherent risks, as it may be

construed as the court giving a different intention than that of the legislature.

Currently, the Act does not explicitly recognize mental health as a ground for

termination. To introduce such a basis through judicial interpretation may therefore

blur the line between interpreting and making law. From the research attached by the

applicants, it is clear that society’s understanding of mental health has advanced and

perhaps, it becomes essential for legal frameworks to evolve in tandem. Mental health

is now widely acknowledged as a critical determinant of individual well-being and once

neglected, woman who suffer from such condition may suffer the impact of unwanted

pregnancies which may come because of abuse. Incorporating mental health

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considerations under the Act would not only align the law with contemporary medical

and ethical standards but also ensure that it continues to serve its intended purpose

effectively. Such a revision would reflect a commitment to upholding the dignity and

rights of all individuals, acknowledging that mental health is integral to overall health.

But the law and morals may be linked but are different-see the famous Hart-Fuller

debate on law and morals.

                Given the Constitution’s transformative purpose and the obligation to

interpret rights generously, the exclusion of mental health as a distinct ground for

lawful abortion raises serious concerns about the effective enjoyment of rights to

dignity, bodily integrity, equality, and freedom from inhuman treatment. If an

exclusionary law cannot be defended as a permissible limitation under s 86(2) of the

Constitution, which requires the restrictive law to be fair, reasonable, necessary, and

justifiable in an open, just and free society, then it will be struck down or require

amendment.

The applicants have well - articulated the impact of the exclusion of mental health as a

ground to access safe abortion. Therefore, s 4 (a) in my view, to the extent that it

excludes mental health, does not meet the standards enunciated in the Constitution

and precedents set on the interpretation of the relevant sections.        It is clear that

women with mental health challenges are treated differently when it comes to the

permissible health related and permitted grounds for termination.


Whether or not s2(1) of the Act in its definition of unlawful intercourse is in

breach of s48, 51, 56(1) of the Constitution in that it excludes lawful abortion from

sexual intercourse proscribed by s106 of the Mental Health Act?


    In relation to the definition of unlawful intercourse, the applicants argue that the

offence is separate and distinct from rape as defined under s 63 of the Code. However,

while s 2(1) of the Act defines unlawful intercourse for the purposes of termination of

pregnancy, pregnancy arising from sexual intercourse prohibited under s 106 of the

Mental Health Act is not expressly included. This omission to recognise such pregnancy

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as resulting from “unlawful intercourse” amounts to a violation of constitutional rights

protected under ss 48, 50, 56(1) and 76 of the Constitution of Zimbabwe.

   Per contra, the first respondent argues that expressly including mental health as a

ground for termination of pregnancy would be discriminatory, as it presumes that all

mental health conditions carry the same prognosis. They further submit that the

Diagnostic and Statistical Manual of Mental Disorders lists over seventy diagnoses,

which may present as mild, moderate, or severe. The first respondent postulates that

most mental health conditions are treatable, and even those requiring long-term

medication allow patients to live stable lives, comparable to individuals managing

other chronic conditions.         Thus, making a blanket assumption that every woman

diagnosed with a mental health condition is incapable of carrying a pregnancy to term

or raising a child would amount to discrimination.

        It is now well established that to be granted relief on the basis that the right

under s 56(1) of the Constitution has been violated, an applicant must prove that they

were denied the same protection of the law which was, however, afforded others in the

same situation – see Nkomo v Minister of Local Government, Rural & Urban Development &

Ors CCZ 6/16.

     The assessment of whether a law or action violates constitutional provisions was

outlined by the authors Currie and De Waal in The Bill of Rights Handbook, 6th ed (2013)

at pg. 133 as follows:

       “Constitutional interpretation is the process of determining the meaning of a constitutional
       provision. More narrowly, for purposes of Bill of Rights cases, the aim of interpretation is to
       ascertain the meaning of a provision in the Bill of Rights in order to establish whether law or
       conduct is inconsistent with that provision. Interpretation therefore involves two enquiries: first the
       meaning or scope of a right must be determined, then it must be determined whether the challenged
       law or conduct conflicts with the right”. (emphasis added)

    The above approach has been adopted by the courts in our jurisdiction, as evinced

by the case of Chituku & Ors v Minister of Lands, Agriculture, Climate and Rural

Resettlement & Ors CCZ 03-23 at pg. 15 paragraph 47:

       “With these principles in mind, the Court must then examine the constitutional provision to determine
       its meaning and interpret the challenged legislation to decide if the alleged violations have been

                                                    18
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       established. This accords with canons of interpretation and has been emphasized time and time by
       the courts in this jurisdiction in a long line of authorities. The approach by the court was settled by
       Judgment No. CCZ 03/23 Constitutional Application No. CCZ 02/22 16 GUBBAY CJ in In Re
       Munhumeso & Ors 1994(1) ZLR 49(S), at 59B-E, where the learned former Chief Justice said the
       following:

       “Two general interpretational principles are to be applied. The first was lucidly expressed by
       Georges CJ in Zimbabwe Township Developers (Pvt) Ltd v Lou‘s Shoes (Pvt) Ltd 1983 (2) ZLR 376 (S)
       at 382B-D; 1984 (2) SA 778 (ZS) at 783A-D, to this effect: ‘Clearly a litigant who asserts that an Act
       of Parliament or a Regulation is unconstitutional must show that it is. In such a case the judicial
       body charged with deciding that issue must interpret the Constitution and determine its meaning and
       thereafter interpret the challenged piece of legislation to arrive at a conclusion as to whether it falls
       within that meaning or it does not . The challenged piece of legislation may, however, be capable of
       more than one meaning. If that is the position then if one possible interpretation falls within the
       meaning of the Constitution and others do not, then the judicial body will presume that the law
       makers intended to act constitutionally and uphold the piece of legislation so interpreted. This is
       one of the senses in which a presumption of constitutionality can be said to arise. One does not
       interpret the Constitution in a restricted manner in order to accommodate the challenged
       legislation. The Constitution must be properly interpreted, adopting the approach accepted
       above. Thereafter the challenged legislation is examined to discover whether it can be interpreted
       to fit into the framework of the Constitution.’

       See also Minister of Home Affairs v Bickle & Ors 1983 (2) ZLR 431 (S) at 441E–H, 1984 (2) SA 39 (ZS) at
       448F–G; S v A Juvenile 1989 (2) ZLR 61 (S) at 89C, 1990 (4) SA 151 (ZS) at 167G–H.” (emphasis added)

     Thus, when a court is faced with a challenge against a particular law on the basis

that it contravenes constitutional rights, the court must establish the scope of the

rights alleged to be infringed and determine whether the impugned law so infringes

constitutional rights. The challenger of any particular law must also provide evidence

of how the constitutional rights have been infringed by the law in question. In casu, the

applicants contend that their right to equal protection of the law contained in s 56(1)

was violated. The section provides that:

       “All persons are equal before the law and have the right to equal protection and benefit of the
       law.”

In interpreting s 56(1), the Constitutional Court in Gonese v Minister of Finance and

Economic Development CCZ 11-23 pg. 22 paragraph 53, held as follows:

       “This Court has, on several occasions in the past, defined the import of the right under s 56(1) of
       the Constitution. In short, it is a non-discrimination provision which guarantees equality before
       the law. It is different from s 18(1) of the former Constitution which provided for a general right to
       the protection of the law. S 56(1) of the Constitution envisages a law which provides for equality in
       the protection and benefit of persons affected by it and the right not to be subjected to conduct
       or treatment to which others similarly placed are not. As remarked in Minister of Justice, Legal and
       Parliamentary Affairs & others v Chinanzvavana & Anor S 119-21, a decision of the Supreme Court of
       Zimbabwe, which no doubt correctly reflects the law in this country, the provision simply
       guarantees equality before the law. A person alleging a violation of a s 56(1) right


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       must not only prove unequal or different treatment but also that others in a similar provision
       were afforded such protection.”

Similarly, in Nkomo v Minister of Local Government, Rural and Urban Development & Ors

CCZ 6-16 pg. 8 it was held that:

       “The right guaranteed under s 56(1) is that of equality of all persons before the law and the right
       to receive the same protection and benefit afforded by the law to persons in a similar position. It
       envisages a law which provides equal protection and benefit for the persons affected by it. It
       includes the right not to be subjected to treatment to which others in a similar position are not
       subjected. In order to found his reliance on this provision the applicants must show that by virtue
       of the application of a law he has been the recipient of unequal treatment or protection that is to
       say that certain persons have been afforded some protection or benefit by a law, which protection
       or benefit he has not been afforded; or that persons in the same (or similar) position as himself
       have been treated in a manner different from the treatment meted out to him and that he is
       entitled to the same or equal treatment as those persons.”

In Moyo v Minister of Local Government, Rural &Urban Development & 2 Ors CCZ 6-16 at

pg. 8, it was held that:

       “In order to found his reliance on this provision the applicants must show that by virtue of the
       application of a law he has been the recipient of unequal treatment or protection that is to say
       that certain persons have been afforded some protection or benefit by a law, which protection or
       benefit he has not been afforded.…...”

     The fundamental principle underlying the right to equal protection and benefit of

the law is that individuals who are in comparable circumstances should not be treated

differently unless there are strong and legitimate reasons that justify such differential

treatment. In this context, the definition of “unlawful intercourse” in s 2(1) of the Act is

problematic, as it does not extend protection to persons who are mentally ill. This

omission results in a discriminatory effect, particularly when considered alongside

other statutory provisions such as s 106 of the Mental Health Act, which expressly

criminalizes sexual intercourse with mentally ill persons on account of their

vulnerability and inability to consent. The inconsistency between these legislative

frameworks undermines the principle of equality before the law. It is, therefore,

imperative that s 2 of the Act be amended to expressly include mentally ill persons

within the scope of “unlawful intercourse,” thereby ensuring that the law provides

consistent and equal protection to all vulnerable groups.

         Further, the applicants contend that the definition of “unlawful intercourse”

contained in s 2 of the Act infringes upon their constitutional right to health care as

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guaranteed under s 76 of the Constitution. Section 76 provides in clear and mandatory

terms that:

       “76 Right to health care

       (1) Every citizen and permanent resident of Zimbabwe has the right to have access to basic health-
       care services, including reproductive health-care services.

       (2) Every person living with a chronic illness has the right to have access to basic healthcare
       services for the illness.

       (3) No person may be refused emergency medical treatment in any health-care institution.

       (4) The State must take reasonable legislative and other measures, within the limits of the
       resources available to it, to achieve the progressive realization of the rights set out in this s.”

        The applicants argue that by excluding mentally ill persons from the statutory

definition of “unlawful intercourse,” s 2 of the Act indirectly denies them full access to

reproductive health-care services. Victims of sexual exploitation who are mentally ill

may face legal and procedural barriers to accessing safe termination of pregnancy,

notwithstanding their heightened vulnerability and inability to provide informed

consent to sexual relations. This undermines subs (1), which guarantees access to basic

health-care services, including reproductive health care, and is inconsistent with the

State’s obligation under subs (4) to enact reasonable legislative measures to

progressively realize this right.

      In effect, the omission creates a category of mentally ill women and girls whose

access to reproductive health care is curtailed, thereby perpetuating inequality and

compounding their vulnerability. Thus, legislative reform is required to harmonise the

Act with the constitutional guarantees under s 76, ensuring that mentally ill persons

are not excluded from the full protection of reproductive health rights.

    The applicants argue that the definition in s 2(1) of the Act is unconstitutional, as it

excludes pregnancies arising from the sexual exploitation of mental health patients

from the definition of “unlawful intercourse”. This exclusion undermines their right to

life under s 48(1), as forcing them to carry such pregnancies may endanger their

physical and mental health, and constitutes a failure by the state to protect vulnerable

individuals.


                                                  21
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        Section 48(1) of the Constitution states that every person has the right to life.

This section guarantees the fundamental right to life, which includes not only

protection from arbitrary deprivation of life but also imposes a duty on the state to

safeguard and preserve the lives of its citizens, particularly those who are vulnerable.

In this case, the applicants argue that s 2(1) of the Act infringes on the right to life

protected under s 48(1) of the Constitution by failing to recognise pregnancies

resulting from the sexual exploitation of mental health patients as arising from

“unlawful intercourse.” Although s 106 of the Mental Health Act criminalizes sexual

relations with mental patients under institutional care, the exclusion of such acts from

the definition of unlawful intercourse denies these women access to legal abortion.

This omission places them at risk of being forced to carry pregnancies that may

threaten their physical and mental health, thereby undermining the state's duty to

protect their lives. By not explicitly including such vulnerable individuals within the

scope of legal protection, the law fails to uphold the right to life, especially for those

who may not be able to consent or protect themselves, thus violating both their dignity

and their constitutional rights.

      In, S v Makwanyane (1995), 1995 (3) SA 391, the Court emphasized the inherent

dignity of every person as part of the right to life, reinforcing the principle that life

should be lived with dignity and not reduced to mere survival.

In that light, it is my considered view that excluding mental health in the definition of

unlawful intercourse, as proscribed in s106 of the Mental Health Act denies women in

such circumstances access to safe abortion services.

What is the remedy?

     The second respondent proposes that the challenges exposed by the applicants

point to the necessity of the Parliament of Zimbabwe to enact laws to remedy them.

This speaks to the doctrine of the separation of powers. This is a foundational

constitutional principle that assigns distinct functions to each branch of government,

thereby ensuring     that the Legislative,      Executive and Judicial arms      operate

independently and without improper interference from one another. Under this
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arrangement, the legislature is responsible for making, amending and repealing laws.

The Executive is tasked with implementing and enforcing those laws. The Judiciary has

the role of interpreting the laws and adjudicating disputes. By vesting separate powers

in each branch, the Constitution aims to prevent the concentration of authority in any

single institution, thereby protecting individual liberty and maintaining a system of

checks and balances within the state.

               While the principle of separation of powers is respected, courts may

exceptionally assume a limited law-making role where it is necessary. This occurs when

judicial intervention is necessary to uphold constitutional rights, fill legal gaps, or

develop the common law in line with evolving social values and constitutional

principles. See Admark Moyo, Basic Tenets of Zimbabwe’s New Constitutional Order. In

Zimbabwe and other common-law jurisdictions, this judicial role is recognized as both

legitimate and, at times, essential.

The author, C. Botha in Statutory Interpretation – An Introduction for Students, 5th ed

(2012) at pg. 162

notes the following concerning the court’s role as a lawmaker:
              “Because of the limitations inherent in language, statutory interpretation necessarily
              involves a type of delegation by the legislature to the judiciary about the final, specific
              application of a general rule. Although the legislature has the main legislative powers,
              those powers are not exclusive, since the courts play a supporting role – the legislature
              and judiciary are partners in the law-making process. This principle was explained very
              well in Zimnat Insurance Co Ltd v Chawanda 1991 (2) SA 825 (ZSC) 832H-I:
                        “It sometimes happens that the goal of social and economic changes is reached
              more quickly through legal development by the judiciary than by the legislature. This is
              because judges have a certain amount of freedom or latitude in the process of
              interpretation and application of the law. It is now acknowledged that judges do not
              merely discover the law, but they also make the law. They take part in the process of
              creation. Law-making is an inherent and inevitable part of the judicial process.”

Thus, courts can engage in law-making in three principal contexts as follows:

      i.   To develop the common law

The Courts may develop the common law incrementally to ensure that judge-made

doctrines align with the Constitution. Section 46(2) of the Constitution expressly

empowers courts to interpret rights in ways that develop the law. The decision in Bhila

v Master of the High Court supra illustrates this, where the High Court departed from
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outdated common-law rules that discriminated against children born out of wedlock,

thereby modernising the law to reflect equality and constitutional justice. In departing

from the common law position, the court held on page 767 C that:

          “The common law position of excluding children born out of wedlock violated the
          constitutional rights to protection of the law and freedom from discrimination. These rights have
          always been in the Zimbabwean Constitution the old Act 1979 and have been more pronounced
          by the wording in the new Act, The Constitution of Zimbabwe Amendment (No. 20) Act 2013. I
          propose to revisit the constitutional provisions after a brief discussion of the Deceased Estate
          Succession Act [Chapter 6:02].”

        ii.   To align the law with constitutional norms

Secondly, courts may act as quasi-legislators when fashioning constitutional remedies.

When statutes are unconstitutional, courts sometimes ‘read in’, ‘read down’ or strike

down the whole provision to cure defects. In the case of Kawenda v Minister of Justice

CCZ 3-22, the Constitutional Court declared ss 70, 76, 83 and 86 of the Criminal Law

(Codification and Reform) Act [Chapter 9:23] unconstitutional as far as they set the age

of sexual consent at 16. It found that the sections did not align with s 81 of the

Constitution, which describes a child as anyone below the age of 18. In that regard, it

found that the provisions failed to protect children between 16- 18 by placing the age

of sexual consent at 16. It was this landmark ruling that saw the age of sexual consent

raised to 18. The court went on to give legislature a period of 12 months to enable

legislature to enact a law that protects all children from sexual exploitation in

accordance with s 81 of the Constitution. This illustrates that even when a court

declares a law to be unconstitutional, it still recognises the legislature’s ongoing role,

giving that branch the space and responsibility to align legislation with constitutional

requirements.

       Further, in the Mudzuri case, supra, the court made a finding that the minimum age

of marriage in Zimbabwe is 18 years, and any marriage entered by a person under the

age of 18 is invalid. Consequently, it declared s 22(1) of the Marriage Act [Chapter 5:11]

unconstitutional in terms of s 78(1) of the Constitution and the section was struck down

as a result thereof.



iii.      To address a gap in the law
                                                    24
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Thirdly, courts may issue temporary rules where necessity and/or legislative silence

threaten fundamental rights. In Zimbabwe, this has never been done, but in India, the

Indian Supreme Court, in the case of Vishaka v State of Rajasthan (1997) 6 SCC 241,

crafted workplace harassment guidelines pending parliamentary action. The court held

that the guidelines were to be treated as a declaration of law in accordance with Article

141 of the Constitution until the enactment of appropriate legislation. Similarly, in

Botswana, in the case of Attorney General v. Unity Dow 1991 BLR 233 (HC), a case that

struck down sexist citizenship laws, the High Court effectively inserted a rule allowing

children of Botswana women to obtain citizenship by descent just as children of

Botswana men could, thereby creating new law on the point. Although Zimbabwe has

not faced an identical situation, however, s 46 of the Constitution empowers courts to

draw on international law and principles to safeguard rights where statutory guidance

is lacking. It provides as follows:

“46. Interpretation of Chapter 4
        (1) When interpreting this Chapter, a court, tribunal, forum or body—
        (a)must give full effect to the rights and freedoms enshrined in this Chapter;
        (b)must promote the values and principles that underlie a democratic society based on openness,
        justice, human dignity, equality and freedom, and in particular, the values and principles set out
        in section 3;
        (c)must take into account international law and all treaties and conventions to which Zimbabwe is
        a party;”



   This encourages the courts to draw from international law. Despite these instances,

courts remain acutely aware of the separation of powers and exercise restraint. In the

case of Magaya v Magaya SC 210-98, in overturning the decision in Katekwe vs

Muchabaiwa 1984 (2) ZLR 112 (SC), the Court stressed that courts must proceed

cautiously in legal interpretation to avoid interfering with the legislature’s domain. It

remarked that:
                “Further, the Courts do not have the capacity to make new law in a complex area of law
                such as inheritance and succession․ Matters of reform should be left to the legislature․
                The role of the Court is simply to uphold the actual and true intention and purport of
                African customary law․”


      Judicial law-making is justified only where necessary to prevent a denial of justice

or to enforce constitutional obligations. It must be narrowly tailored, provisional, and


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grounded in identifiable legal sources rather than policy preference. The South African

Constitutional Court has observed in S v Manamela 2000 (1) SACR 414 (CC), judicial

remedies are not the “final word,” as the democratic lawmaker remains free to legislate

further within constitutional bounds. Similarly, in National Coalition for Gay and Lesbian

Equality v Minister of Home Affairs supra, the court held at p. 61 on para 76 that:
                “[76] It should also be borne in mind that whether the remedy a court grants is one
              striking down, wholly or in part; or reading into or extending the text, its choice is not
              final. Legislatures are able, within constitutional limits, to amend the remedy, whether by
              re-enacting equal benefits, further extending benefits, reducing them, amending them,
              “fine-tuning” them or abolishing them. Thus, they can exercise final control over the
              nature and extent of the benefits.”

Therefore, the democratic lawmaker can adjust the law afterwards within constitutional

bounds.

       In addition, courts respect the legislature’s democratic legitimacy and policy-

making competence, particularly where complex social or budgetary choices are

involved. In Minister of Health v Treatment Action Campaign 2002 (5) SA 721 (CC), the

South African Court set constitutional baselines for access to medication without

prescribing a detailed policy demonstrating that courts can enforce rights robustly

while avoiding overreach.

                 Courts, therefore, can and do play a law-making role, but only in

constitutionally compelled circumstances to update the common law, remedy

unconstitutional statutes, or fill legal vacuums that threaten fundamental rights. This

role is exercised with caution, transparency, and deference to the legislature’s primary

authority. In Zimbabwe, judicial law-making functions are a necessary complement to

legislative power, ensuring that the law remains living, just and rooted in the spirit of

the Constitution while maintaining the delicate balance of the separation of powers.

   The powers of courts in constitutional matters are, set in s175 of the Constitution as

follows,


              “175. Powers of courts in constitutional matters




                                                 26
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              (1) Where a court makes an order concerning the constitutional invalidity of any law or
              any conduct of the President or Parliament, the order has no force unless it is confirmed
              by the Constitutional Court.

              (2) A court which makes an order of constitutional invalidity referred to in subsection (1)
              may grant a temporary interdict or other temporary relief to a party, or may adjourn the
              proceedings, pending a decision of the Constitutional Court on the validity of the law or
              conduct concerned.

              (3) Any person with a sufficient interest may appeal, or apply, directly to the
              Constitutional Court to confirm or vary an order concerning constitutional validity by a
              court in terms of subsection (1).

              (4) If a constitutional matter arises in any proceedings before a court, the person
              presiding over that court may and, if so requested by any party to the proceedings, must
              refer the matter to the Constitutional Court unless he or she considers the request is
              merely frivolous or vexatious.

              (5) An Act of Parliament or rules of court must provide for the reference to the
              Constitutional Court of an order concerning constitutional invalidity made in terms of
              subsection (1) by a court other than the Constitutional Court.

              (6) When deciding a constitutional matter within its jurisdiction a court may—
              (a) declare that any law or conduct that is inconsistent with the Constitution is invalid to
              the extent of the inconsistency;
              (b) make any order that is just and equitable, including an order limiting the retrospective
              effect of the declaration of invalidity and an order suspending conditionally or
              unconditionally the declaration of invalidity for any period to allow the competent
              authority to correct the defect.”

        Mr Biti submitted that in terms of the remedies, should the court declare the

provisions unconstitutional, a ‘reading in’ should be employed. ‘Reading in’ is a judicial

remedy whereby the court will ‘read’ something into the meaning of a provision in

order to rescue a provision or a part of it. See C. Botha, Statutory Interpretation – (supra

@197). This may be through the addition of words or provisions to a statute to keep it

constitutional, as opposed to striking down the statute or a portion of it outright. When

a court finds that a statute violates the Constitution due to under-inclusiveness or

exclusion, it can remedy this by reading the omitted group or condition into the statute

to achieve compliance with the Constitution while preserving the overall statute.

        While section 175 of the Constitution empowers courts to declare legislation

invalid to the extent of inconsistency with the Constitution, the text does not explicitly

mention ‘reading in,’. Courts though have an inherent authority to craft appropriate

remedies, and “just and equitable orders” when upholding fundamental rights. In

Mudzuru & Anor v Ministry of Justice, Legal & Parliamentary Affairs N.O. & Ors supra, the


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Court effectively read s 78(1) of the Constitution into the Marriage Act [Chapter 5:11], to

the effect that no person under 18 can found a family. The Court declared that the

Marriage Act must be understood as prohibiting any marriage of persons under the

age of 18. Although framed as an invalidation of the Marriage Act’s lower marriage

age, the result was to insert the Constitution’s 18-year age of majority. This shows the

Court ensuring that the statute aligns with the constitutional requirement by adding

the missing protection.

        In comparison, s 172 of South Africa’s Constitution explicitly allows courts to make

“any order that is just and equitable,” which the South African Constitutional Court has

interpreted as permitting reading-in when appropriate. Since Zimbabwe’s Constitution

and jurisprudence do not expressly codify the remedy of reading in, the courts can

draw guidance from South African precedent given the shared constitutional

framework, similar rights-based provisions and the common Roman Dutch legal

heritage underlying both systems. In the South African case of National Coalition for

Gay and Lesbian Equality and Ors v The Minister of Home Affairs 1999 (3) SA 173 (C), held

that:
                “[70] I accordingly conclude that reading in is, depending on all the circumstances, an
                appropriate form of relief under section 38 of the Constitution and that “. . . whether a
                court ‘reads in’ or ‘strikes out’ words from a challenged law, the focus of the court should
                be on the appropriate remedy in the circumstances and not on the label used to arrive at
                the result.” The real question is whether, in the circumstances of the present matter,
                reading in would be just and equitable and an appropriate remedy.”
  Similarly, the Supreme Court of Canada, under its constitutional supremacy clause, s

52 of the Constitution Act, 1982, has asserted that reading in is a legitimate exercise of

its power to strike down unconstitutional laws, being essentially an alternative way to

render the law constitutional. Notably, in Schachter v Canada [1992] 2 SCR. 679, the

Canadian Supreme Court set out a framework for choosing remedial techniques and

confirmed that reading in is a legitimate remedy akin to severance in appropriate

cases.

Courts will consider reading in when the following conditions are generally met:

           i.   The constitutional infirmity arises from an omission or exclusion, that is,

                the statute is underinclusive, extending benefits or protections only to a
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               certain class and           leaving      others    unprotected without sufficient

               justification;

         ii.   Adding words would correct the violation in a manner that minimally

               alters the legislation and furthers the legislative purpose, rather than

               detracting from it; and

        iii.   The court can fairly identify the precise words or category to be added so

               that it is confident the result aligns with what the legislature would have

               intended had it been aware of the constitutional requirement.

These considerations were established in National Coalition for Gay and Lesbian Equality

and Ors v The Minister of Home Affairs supra on p. 60 para 74-75 as follows:
               “[74] The severance of words from a statutory provision and reading words into the
               provision are closely related remedial powers of the Court. In deciding whether words
               should be severed from a provision or whether words should be read into one, a court
               pays careful attention first, to the need to ensure that the provision which results from
               severance or reading words into a statute is consistent with the Constitution and its
               fundamental values and secondly, that the result achieved would interfere with the laws
               adopted by the legislature as little as possible…
               … [75] In deciding to read words into a statute, a court should also bear in mind that it will
               not be appropriate to read words in, unless in so doing a court can define with sufficient
               precision how the statute ought to be extended in order to comply with the Constitution.
               Moreover, when reading in (as when severing) a court should endeavour to be as faithful
               as possible to the legislative scheme within the constraints of the Constitution. Even
               where the remedy of reading in is otherwise justified, it ought not to be granted where it
               would result in an unsupportable budgetary intrusion.”


Therefore, a court may validly “read in” missing provisions into a statute to remedy an

unconstitutional exclusion only were doing so is necessary to uphold constitutional

rights without encroaching upon the legislature’s policy-making function. The remedy

is governed by principles of constitutional restraint, proportionality, and institutional

competence.

     Courts apply this remedy cautiously, ensuring that ‘reading in’ does not amount to

legislating new policy choices or imposing obligations that Parliament never

contemplated. A key consideration is the scope and practical impact of extending the

law to the excluded group. As emphasised in the National Coalition for Gay and Lesbian
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Equality v Minister of Home Affairs judgment, even where discrimination is evident, a

court should refrain from reading in if doing so would create significant budgetary or

administrative burdens that courts are ill-equipped to evaluate. Before invoking the

remedy, the court must consider additional factors such as the size and nature of the

group being aided, whether inclusion would fundamentally alter the legislative scheme

or merely extend it in line with its underlying purpose and whether the extension

would have substantial fiscal or policy implications better assessed by Parliament. In National
Coalition for Gay and Lesbian Equality v Minister of Home Affairs supra, the court held that:

                  “Even where the remedy of reading in is otherwise justified, it ought not to be granted
                  where it would result in an unsupportable budgetary intrusion.101 In determining the
                  scope of the budgetary intrusion, it will be necessary to consider the relative size of the
                  group which the reading in would add to the group already enjoying the benefits. Where
                  reading in would, by expanding the group of persons protected, sustain a policy of long
                  standing or one that is constitutionally encouraged, it should be preferred to one
                  removing the protection completely.”

            If the excluded group is small or the extension aligns with established

constitutional values or long-standing policy, ‘reading in’ is usually deemed

appropriate. However, where adding a group would transform the structure or

objectives of the law or require complex policy judgments, such as reallocating public

funds or creating new administrative systems, the court will instead declare the

provision invalid and suspend the declaration to give the legislature time to enact a

suitable amendment.

       In the South African case of Hassam v Jacobs NO and Others 2009 (5) SA 572 (CC),

the Maintenance of Surviving Spouses Act extended inheritance rights only to surviving

spouses in monogamous civil marriages, excluding widows from polygynous Muslim

marriages. The Court found this exclusion discriminatory on grounds of religion and

marital status. To cure the defect, it read in words to extend the Act’s protection to

surviving spouses in polygynous Muslim marriages. This targeted remedy ensured

substantive equality without overstepping judicial boundaries or altering the legislative

scheme’s core purpose.

           Comparatively, the leading Canadian case of Vriend v Alberta [1998] 1 SCR 493

exemplifies this approach. Alberta’s human rights legislation listed several prohibited

grounds of discrimination but omitted “sexual orientation.” The omission effectively
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denied protection to LGBT individuals, amounting to unconstitutional exclusion under

the Canadian Charter’s equality clause. The Supreme Court of Canada held that

“reading in” sexual orientation was the appropriate remedy, as it directly addressed the

under-inclusiveness while preserving the broader statutory framework. Striking down

the entire Act, as suggested by the government, would have removed protections for

all other groups, a result clearly contrary to legislative purpose. The Court emphasised

that reading in was justified because it advanced the statute’s objective, which is

protecting individuals from discrimination, corrected a specific constitutional flaw and

minimised disruption to the law’s operation.

        These cases illustrate that the remedy of ‘reading in’ is appropriate only under

specific, carefully defined conditions. It may be employed where the exclusion in a

statute violates a constitutional right, the remedy aligns with the statute’s underlying

purpose, and the addition to the law is narrow, precise, and necessary to achieve

equality. Importantly, the modification must not impose new policy choices, fiscal

obligations, or administrative burdens that are more properly the responsibility of the

legislature. In such circumstances, courts apply “reading in” to cure an unconstitutional

omission in a manner that preserves legislative intent, promotes constitutional

compliance, and ensures minimal interference with the democratic process. While

there is not yet an extensive record of reading-in remedies by Zimbabwe’s

Constitutional Court, the judiciary can draw on the above principles.

        Where the application falters however is on relief sought. A fundamental

procedural defect arises from the fact that the relief sought by the applicants is not

framed with sufficient precision. In their founding affidavit, the applicants argue that s

4(a) is ultra vires the Constitution in that it excludes mental health as a permissible

ground for abortion. However, their relief is not directed at securing the inclusion of

mental health as a ground under the impugned section. Instead, they merely seek a

blanket declaration of invalidity of the section. Similarly, with respect to s 2(1), the

applicants seek that the section as a whole be declared unconstitutional, yet in their

founding affidavit, they argue that it is unconstitutional only as far as mental health is

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not a ground for termination. On that basis, there is no reason to strike down the

entire s 2 (1). The proper relief should have been to seek a reading of mental health

under s 2(1), or that Parliament be afforded an opportunity to amend the law rather

than a complete striking from the definition. Let me hasten to state that despite the

order sought not being drafted elegantly, I see no prejudice suffered by the

respondents especially since the court has already found that the impugned sections

are unconstitutional.

        Whilst a reading in for both s4(a) and 2(1) of the Act would also be proper, I am

hesitant for the court to play the role of a lawmaker. As enunciated in various cases,

this power should be exercised with restraint lest it results in unintended

consequences. The respondents should be afforded an opportunity to properly frame

the law, taking into account the order of the court. I take guidance from the Kaweda

case (supra) and allow the respondents a time frame within which to affect the

amendments.

COSTS

This matter has raised critical issues relating to protection of rights in the Constitution.

Guided by s63(1) of the Constitutional Court Rules, 2025, I will not make any order as to

costs. See also Nkomo vs. Minister of Local Government, Rural and Urban Development

and ors, CC-06-16.




DISPOSITION

   1. The definition of unlawful intercourse in s2(1) of the Termination of Pregnancy
      Act [ Chapter 15:10] is declared unconstitutional only to the extent that it
      excludes mental health and conduct proscribed in s106 of the Mental health Act
      [Chapter 15:12] in the definition of unlawful intercourse.

   2. Section 4(a) of the Termination of Pregnancy Act [Chapter 15:10] is declared
      unconstitutional only to the extent that mental health as a ground for lawful
      termination of pregnancy is excluded.

   3. The orders of constitutional invalidity made in paras (2) and (3) above are hereby
      suspended for 18 months from the date of this order to enable the respondents

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       to amend the provisions in the Termination of Pregnancy Act as cited in
       paragraphs one and two above to include mental health and conduct proscribed
       in s106 of the Mental Health Act.

   4. The above declarations of constitutional invalidity are suspended until such time
      as the Constitutional Court has confirmed the same in terms of section 167(3) of
      the Constitution of Zimbabwe.

   5. The above order of constitutional invalidity is referred to the Constitutional
      Court for confirmation in terms of section 175 (1) of the Constitution.

   6. There shall be no order as to costs.




Tendai Biti Law, applicants’ legal practitioners

Civil Division of the Attorney-General’s Office, 1-3rd respondents’ legal practitioners




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