among the State to use its powers to curtail the liberty of the citizens without following procedures set out in the law. The detainee was discharged. ARTICLE 7: EQUALITY BEFORE THE LAW The Constitution of the United Republic of Tanzania, of 1977 under Article 13(6)(a), guarantees the right to be heard in order to ensure equality before the law. In order to achieve this goal, the State has a duty to make policies and enact laws to the effect that when the rights and duties of any person are being determined by the court of law or any other body, such a person has the right to be fairly heard and to appeal against the decision of the court or such other body. This provision gives the rules of natural justice special status in the Tanzanian legal system. Courts of law has emphasised this position in the process of determining the rights of individuals. For example in the case of Mahona Vs University of Dar es Salaam (1981) TLR at page 55, the applicant was terminated from employment by the defendant on disciplinary grounds. He complained that he was not given an opportunity to bt:_ heard. Agreeing with the applicant Kisanga J, as he then was, confirmed that there was breach of the rules of natural justice as the grounds of appeal by the defendant were not made known to the plaintiff by the Minister and the same Minister proceeded to determine the appeal without hearing the applicant. The judge underlined the importance of the rules of natural justice and indicated that non-adherence to these rules renders the decision made null and void. Similarly, in Jimmy David Ngonya vs. National Insurance Corporation LTD [1994] T.L.R. 28, the app licant was dismissed from employment as a branch manager of the respondent corporation. The Board of Directors dismissed him on the basis of an audi t report whose contents were never shown to the applicant to enable him to contradict them. When the Board of Directors met to deliberate on the applicant's case, the General Manager, :-vho had initiated the proceedings against the applicant and had commissioned 14