(2017) 1 African Human Rights Yearbook 69 representation of women in public service improved significantly, to reach 31 per cent in 2014.42 Quotas are one of the special measures to improve women representation under article 9 of the Protocol. The Constitution introduced quotas to guarantee women representation in Senate and Parliament under section 12043 and 124, respectively.44 Specifically, section 120(2)(b) stipulates that elections of senators to be conducted under a party-list system of proportional representation ‘in which male and female candidates are listed alternately, every list being headed by a female candidate.’ Similarly, section 124(1)45 provides for ‘an additional sixty women members, six from each of the provinces into which Zimbabwe is divided, elected through a system of proportional representation based on the votes cast for candidates representing political parties in a general election for constituency members in the provinces’. The introduction of constitutional quotas has the effect of improving numerical equality of men and women National Assembly. All the countries that have achieved or exceeded 30 per cent representation of women in Southern Africa – Lesotho (58 per cent), Mozambique (35, 6 per cent), South Africa (40 per cent), Tanzania (34 per cent) and Namibia (42 per cent) have some form of quota.46 In Zimbabwe, the introduction of constitutional quotas increased women representation from 14.29 per cent in 2008 to 32 per cent in 2013 (Parliament), and from 24.2 per cent to 48 per cent (Senate).47 With the introduction of this constitutional quota, Zimbabwe improved on the Inter Parliamentarian Union (IPU) World Classification of women in national parliaments: from 90 out of 190 countries in 2012 to 27 out of 190 after the 2013 elections.48 This improvement is commendable even though it remains below the 50-50 appeal of African Women’s Rights Protocol. In appointing Ministers and Cabinet, the President of Zimbabwe is guided by considerations of gender balance.49 With section 104(4) of the Constitution requiring gender balance, leaders are constantly reminded of this need in all appointments. In a way, inclusion of a provision on gender balance has given impetus for advocacy in cases where political leaders have reneged in ensuring gender balance in their appointments. In 2013, feminists and scholars made headlines accusing the President of Zimbabwe for appointing a male-dominated Cabinet with only three women out of the 26 Ministers, arguing that 42 First Report of the Portfolio Committee on Women Affairs, Gender and Community Development on Ministry of Women Affairs, Gender and Community Development’s Programmes, Activities and Challenges and Gender Mainstreaming in Government Line Ministries, Parliament of Zimbabwe, September 2014. 43 Section 120(2)(a) of the Constitution of Zimbabwe. 44 Section 124 of the Constitution of Zimbabwe. 45 See Section 124 of the Constitution of Zimbabwe. 46 Gender Links (n 14 above) 38. 47 Gender Links (as above). 48 Inter-Parliamentary Union ‘Women in National Parliaments’ 2013 http://www.ipu. org/wmn-e/arc/classif011213.htm (accessed 11 June 2017). 49 See section 104(4) of the Constitution of Zimbabwe.

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