70 Zvobgo and Dziva/African Women’s Rights Protocol in Zimbabwe this position is against section 17 of the Constitution.50 Using section 17 and 10451of the Constitution as the basis of their argument, feminists and other scholars denounced this move by the President as a mere lack of political will for constitutionalism. Persistent calls by activists contributed to numerous subsequent Cabinet reshuffles, which saw an improvement in women representation from three in 2013,52 to four female Ministers as of September 2017.53 Similarly, President Robert Mugabe rejected the proposed boards for state-owned Zimbabwe Mining Development Corporation, the Minerals Marketing Corporation of Zimbabwe, and Marange Resources in 2015 on the basis of it being not gender balanced in violation of section 17 of the Constitution and article 9 of the Protocol.54 3.2 National policy reforms The National Gender Policy (2013-2017) is the key policy with regard to women participation in politics and decision-making processes in Zimbabwe. It is noteworthy that the Policy mentions the African Women’s Rights Protocol on several occasions. In line with the Protocol, the AU Gender Policy and the African Women’s Decade, the Policy calls for the ‘inclusion and active participation of women in politics and decision-making processes’.55 The closest the Policy mirrors article 9 of the African Women’s Rights Protocol is when it sets out women’s participation in politics and decision-making as one of the eight priority areas.56 Above all, the Policy recognises women as equal partners in socio-economic and political development, and calls for their full participation in public life. One set activity under the Policy’s 50 B Dube & C Dziva ‘The appointment of 2013 Cabinet Ministers in Zimbabwe: a lost opportunity for gender parity in decision-making positions’ (2014) 5 International Journal of Politics and Good Governance 1. 51 Section 104(4) of the Constitution of Zimbabwe states that ‘[i]n appointing Ministers and Deputy Ministers, the President must be guided by considerations of … gender balance’. 52 The 3 women ministers were: Olivia Muchena, Higher and Tertiary Education, Science and Technology Development; Oppah Muchinguri, Minister of Women Affairs, Gender and Community Development, and Sithembiso Nyoni, Minister of Small and Medium Enterprises and Co- operatives. 53 The 4 women ministers after the reshuffling in 2015 are: Prisca Mupfumira, Ministry of Public Service Labour and Social Services; Nyasha Chikwinya, Ministry of Women’s Affairs, Gender and Community Development, Oppah Muchinguri, Ministry of Environment Water and Climate, and Sithembiso Nyoni, Minister of Small and Medium Enterprises and Co- operatives. 54 ‘Outrage over Cabinet gender bias’ The Independent 20-26 September 2013; ‘President Mugabe appoints new Cabinet’ 10 September 2013 http://www.herald.co.zw/ breaking-news-president-mugabe-set-to-announcecabinet/ (accessed 20 June 2017); ‘Mugabe excuses of gender bias lame’ The Independent, 27 September to 3 October 2013. 55 The National Gender Policy (2013-2017) (Ministry of Women Affairs, Gender and Community Development: Harare 2013) www.women.gov.zw/downloads?download =3:2013-national-gender-policy (accessed 20 June 2017). 56 National Gender Policy (n 55 above).