I, CUTHBERT TAPUWANASHE CHAWIRA do hereby make oath and state that:-

I am the First Applicant in this matter.  The facts I depose hereto are fully within my knowledge and to the best of my belief true and correct.  To the extent that I make many averments of law and research, I do so, on the basis of advice from counsel which advice I fully accept. 

First Applicant's Answering Affidavit in Chawira & 13 Others v Minister of Justice & 2 Others.

The Applicants make the following further submissions in response to the Respondents’ Heads of Argument.

APPLICANTS’ CASE IN SUMMARY

IN THE CONSTITUTIONAL COURT OF ZIMBABWE HELD AT HARARE

In the matter between:-

OBADIAH MAKONI                                                                         APPLICANT

and

THE COMMISSIONER OF PRISONS                                                  1^ST RESPONDENT

MINISTER OF JUSTICE, LEGAL & PARLIAMENTARY AFFAIRS            2^ND RESPONDENT

IN THE CONSTITUTIONAL COURT OF ZIMBABWE HELD AT HARARE

In the matter between:-

OBEDIAH MAKONI                                                                        APPLICANT

AND

THE COMMISSIONER OF PRISONS & CORRECTIONAL SERVICE                          1^ST RESPONDENT

THE MINISTER OF JUSTICE, LEGAL & PARLIAMENTARY AFFAIRS                     2^ND RESPONDENT

IN THE CONSTITUTIONAL COURT OF ZIMBABWE HELD AT HARARE

In the matter between:-

OBADIAH MAKONI                                                                       APPLICANT

AND

THE COMMISSIONER OF PRISONS                                                             1^ST RESPONDENT

THE MINISTER OF JUSTICE, LEGAL & PARLIAMENTARY AFFAIRS                2^ND RESPONDENT

Respondents' Supplementary Heads of Argument in Makoni v The Commissioner of Prisons and Another.

I, FARAI LAWRENCE NDLOVU do hereby make oath and state that:-

I am the First Applicant in this matter.  The facts I depose hereto are fully within my knowledge and to the best of my belief true and correct.  Where I make averments of law, I do so, on the basis of advice from counsel which advice I fully accept. 

THE ACTORS