BE PLEASED TO TAKE NOTICE THAT, the Appellant hereby appeals against the whole judgment of the High Court of Zimbabwe sitting at Harare handed down by Zhou J, Charewa J, and Mushore J in case number HC 2166l2I on 16 May 2021. A copy of the judgment is attached hereto. No leave to appeal is necessary.

FURTHER TAKE NOTICE THAT the Appellant's address for service for the purposes of this appeal is that of its legal practitioners of record, Attorney General's Office, 3rd Floor, Block A, New Government Complex, Cnr Samora Machel Avenue and Fourth Street, Harare.

FURTHER TAKE NOTICE THAT:  a) The Appellant tenders security for the Respondents’ costs of the appeal as may be agreed upon between the parties or failing such agreement as may be determined by the Registrar of this Honourable Court. The Appellant undertakes to pay the costs for the preparation of the record of appeal as soon as it has been advised of such costs by the Registrar of the Honourable Court.

FURTHER TAKE NOTICE THAT the grounds upon which the appeal is made are the following:- .1. The High Court erred in finding that the 1st Applicant before it (the 1st Respondent herein) had locus standi to obtain the relief that it granted in the absence of evidence of the violation or potential violation of its members' right to equal protection and benefit of the law in terms of section 56 (1) or the right not to be treated unfairly in terms of section 56 (3) or the right to access courts established in terms of the law enshrined in section 69 (3) of the Constitution of Zimbabwe.

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