AN ANALYSIS OF THE CONFLICT BETWEEN CHILDREN’S RIGHTS AND

UKUTHWALA IN SOUTH AFRICA

By

Student Name

(Student Number)

Submitted in partial fulfilment of the requirements for the degree

LLB

In the

SCHOOL OF LAW

NAME OF UNIVERSITY

SUPERVISOR: NAME OF SUPERVISOR

(PORTFOLIO ASSIGNMENT NUMBER)

(YEAR / DUE DATE)

TABLE OF CONTENTS

1. ACADEMIC HONESTY DECLARATION .......................................................... 3

2. INTRODUCTION ............................................................................................... 4

3. PROBLEM STATEMENT .................................................................................. 5

4. HYPOTHESIS ................................................................................................... 6

5. POINTS OF DEPARTURE AND ASSUMPTIONS ........................................... 7

6. CONCEPTUALISATION OF CENTRAL RESEARCH THEMES 10 ..................

7. PROPOSED CHAPTER OUTLAY .................................................................. 11

8. PROJECTED TIME FRAME ........................................................................... 12

9. DESCRIPTION OF PROPOSED RESEARCH METHODOLOGY ................ 12

10. CONCLUSION ................................................................................................. 13

11. BIBLIOGRAPHY ................................................................................................................ 14

2
ACADEMIC HONESTY DECLARATION FOR LME3701 PORTFOLIO EXAM

1. I understand what academic dishonesty entails and am aware of Unisa’s policies

in this regard.
2. I declare that this assignment is my own, original work. Where I have consulted
someone else’s work, I acknowledged their work by referring to it in a footnote.
Every contribution to, and quotation in, this assignment from the work or works
of others have been referenced according to the prescribed style.
3. I have not allowed, and will not allow, anyone to copy any part of my work for
the purpose of passing it off as his or her own work.
4. I did not make use of any part of another student’s work in order to submit it as
my own.

NAME:
______________________________________________________________
SIGNATURE:
________________________________________________________
STUDENT NUMBER:
__________________________________________________
MODULE CODE:
_____________________________________________________
DATE:
______________________________________________________________
RESEARCH THEME SELECTED:
________________________________________
MARK RECEIVED FOR ASSIGNMENT 01:
________________________________
MARK RECEIVED FOR ASSIGNMENT 02:
_________________________________

INTRODUCTION

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End Child Marriage is a groundbreaking initiative that rightfully calls attention to end
the practise of child marriages. It is a global campaign led by Girls Not Brides 1 in
partnership with The African Union 2; and according to the United Nations International
Children's Emergency Fund (hereinafter referred to as UNICEF), “more than 100
million girls are expected to marry before their eighteenth birthday in the next decade”
(UNICEF, 2022). 3 India accounts for the largest number of child brides in the world,
with 15.6 million women married before 18 y/o, followed by Bangladesh and Nigeria
with 4.4 million and 3.7 million respectively (Statista, 2023). 4

“Child brides are mostly found among the most illiterate segments of the population in
rural areas” (UNICEF) 5 where harmful practises such as ukuthwala are embedded in
the culture, therefore, commonly practised. This means that any efforts or attempts at
social reform to end child marriage becomes a rather challenging task since it poses
“a clear conflict between children's rights and cultural rights” (Prof Mwambene). 6

Nonetheless, much has been done to rectify this harmful practise, and in South Africa,
various legislation has been put in place such as section 28(2) of the Constitution of
the Republic of South Africa, 1996 (hereinafter referred to The Constitution), 7 and
especially the Recognition of Customary Marriages Act (hereinafter referred to as
Customary Marriages Act) which prescribes the legal marriage age to 18 y/o for girls
and boys.8 Even though legislation exists, the researcher agrees with many other
human rights scholars that, the implementation of these laws is often hindered by
cultural practices such as ukuthwala that are criminal in every sense but hidden under

1 Girls Not Brides is a global partnership of more than 1600 organisations in over 100
countries committed to ending child marriages around the world
<https://www.girlsnotbrides.org/ > accessed May 2023
2 The African Union Campaign to End Child Marriage was launched in 2014
<https://au.int/en/sa/cecm > accessed May 2023
3 UNICEF ‘Child marriage threatens the lives, well-being, and futures of girls around
the world’ 2022 <https://www.unicef.org/protection/child-marriage> accessed March
2023
4 Statista ‘highest absolute numbers of child marriages as of 2020, Feb 2023
<https://www.statista.com/statistics/1228332/highest-absolute-number-of-girl-brides-by-
country/> accessed 20 March 2023
5 UNICEF, “A Profile Of Child Marriage in Africa”, 2015 <tps://data.unicef.org/resources/a-
profile-of-child-marriage-in-africa/ > accessed April 2023
6 Mwambene L, “Recent legal responses to child marriage in Southern Africa: The case of
Zimbabwe, South Africa and Malawi”, 2018 < http://www.scielo.org.za/scielo.php > accessed
May 2023
7 Sec 28(2) Constitution of the Republic of South Africa, 1996

8 Sec 3(1) of the Recognition of Customary Marriages Act 120 of 1998

4
the guise of culture.

In view of the above, this research intends to provide an in-depth analysis into the
legal framework of children’s rights in South Africa, both historically and current. Our
aim is to probe the validity and cultural practise of ukuthwala, highlight the conflict
between legislation pertaining to the protection of children's rights and cultural
practices that lead to child marriages. We will also explore how ukuthwala digressed
from a traditional custom of initiating a marriage proposal to a shameful criminal act
that violates our children’s rights, shields paedophiles and results in sexual
exploitation of children and a broken society.
The research is divided into four chapters including the introduction. The second
chapter critically analyses the historical development of various laws pertaining to
childcare by highlighting certain inadequacies within the legal framework as it relates
to the protection of children. The third chapter will focus on the laws that permits the
cultural practise of ukuthwala, the role of traditional leaders as well as the conflicts in
legislature and how South Africa’s legal framework is addressing the conflict so as
protect children’s rights and end child marriages. The last chapter provides the
conclusion and recommends clear guidelines that could be enforced to prevent
harmful cultural practises and end child marriages.

PROBLEM STATEMENT

The researcher aims to uncover whether culture can be used as a defence against
criminal prosecution to justify the practice of an offensive cultural practise like
ukuthwala. A comprehensive analysis of South African laws on children’s rights from
past to present legislation will be evaluated so as to (a) determine their current
relevance in relation to cultural practises; and (b) evaluate the historical development
of these laws pertaining to children’s rights in the South African criminal justice system.

Accordingly, this research focuses on the legislative framework, law reform

commission reports, case law and writings by scholars in order to provide insights on
how the law deals with cultural issues that impede the implementation of these laws
resulting in the violation of human rights. Lastly, the constitutional rights of children
juxtaposed against the backdrop of customary marriages will also be considered and
in this regard, the researcher will explore the following aspects:

5
 1. What is the impact of current child legislation in relation to culture, the Bill of
Rights and the values enshrined in the Constitution?
2. Which constitutional rights play a part in the protection of children?
3. Should cultural offenders be protected in South Africa and how does that
contribute to the evolution of culture?

Even though there is legislative framework to deal with the challenge of ukuthwala
and child marriages, the main legal question we wish to address from this research is,
if our Constitution provides for the protection of children as paramount and also
permits the cultural practise of ukuthwala ; does it mean the interest or definition of
child, as defined in the Children’s Act, should be disregarded in matters involving
culture or are our beautiful cultures used by dangerous men to simply commit criminal
acts of kidnapping, rape and a violation of human rights under the guise of culture? Is
ukuthwala even constitutional given existing case laws and the definition of child or
does South African need specific laws that deal with child and customary marriages?

HYPOTHESIS

Even though children's rights have undergone a remarkable change since South Africa
became a constitutional democracy, it is clear that there is a significant need for
coordinated efforts to reform the criminal justice system when dealing with children in
South Africa. The South African Constitution incorporates an extensive Bill of Rights,
9 where children are also included under “all people”; but it also places an obligation
on the State to respect, promote and fulfil these rights. The South African government
has put in place legislation such as The Children’s Act 38 2005 (hereinafter referred
to as the Children’s Act)101112 and other measures to prohibit harmful cultural
practices on children, including the historic the case of Jezile v. S and Others (A
127/2014) 2015 ZAWCHC, where the defendant, a 28 year old man, was convicted in
the Wynberg regional court on one count of human trafficking, three counts of rape
and one count of assault following an arranged customary marriage with the

9 Currie I and de Waal J, The Bill of Rights Handbook (6th edition, Juta 2005)
10 The Children’s Act 38 of 2005
11 Domestic Violence Act 116 of 1998
12 Family Law and Sexual Offences and Related Matters Act 23 of 1957

6
complainant's uncle which led to her abduction. The complainant was only 14 y/o at
the time (SAFLII, 2015). 13

POINTS OF DEPARTURE AND ASSUMPTIONS

In order to explain the laws applicable to the protection of children from a historic
perspective through to current day, the researcher explores how South Africa is
responding to the obvious conflict between the protection of children’s rights and
harmful cultural practices such as ukuthwala that lead to child marriages. The research
conducted focuses on historical developments, and also highlights the theoretical
problems that law makers face in relation to children’s rights versus customary laws
and how to address those gaps.

The research is conducted against the backdrop of the South African Constitution
14and it is specific to South Africa only. We make use of various South African case
laws and legislation as primary sources; and also highlight several legal challenges
and conflicts. Literature published through secondary sources such as electronic
sources, academic journals, scholarly and journal articles were also analysed.
Furthermore, the researcher critically reviews academic reports, case laws, scholarly
15
articles, and the South African Law Commission Reform Reports to provide
recommendations and a broad analysis of the issue. We also highlight certain
inadequacies within the legal framework as it relates to the protection of children.

According to UNICEF, child marriage refers to any formal or informal union between
a child under the age of 18 and an adult or another child (UNICEF).16 The Department

13 SAFLII ‘Jezile v. S and Others (A 127/2014) 2015 ZAWCHC <

http://www.saflii.org/za/cases/ZAWCHC/2015/31.html > accessed 22 March 2023
14 The Constitution
15 South African Law Reform Commission Reports Revised Discussion Paper 138 Project
138 The Practice of ukuthwala <https://www.justice.gov.za/salrc/dpapers/dp132-
ukuthwala revised.pdf> accessed 20 March 2023
16 UNICEF ‘Child marriage threatens the lives, well-being, and futures of girls around
the world’ 2022 < https://www.unicef.org/protection/child-marriage > accessed 20
March 2023

7
of Justice and Constitutional Development (hereinafter referred to as DOJ) defines
ukuthwala as an age-old Xhosa marriage custom which involves the abduction of a
young girl by a man who intends to marry her (justice.gov.za). 17 “Traditionally, the act
of ukuthwala, was not with impunity; it incurred delictual liability in the form of dowry.
However, currently ukuthwala increasingly involves kidnapping, rape and forced
marriage of minor girls as young as twelve years, by grown men old enough to be their
grandfathers” (justice.gov.za).18 In South Africa, various legislation has been put in
place to end child marriages such as section 28(2) of the South African Constitution
which notes that “a child’s best interest is of paramount importance in every matter
concerning the child”; 19 and The Children’s Act 38 of 2005 further emphasizes the
prevention of child marriages.20 “The Domestic Violence Act states that a victim of
ukuthwala can apply for a protection order under its law,21 while Criminal Law provides
that a girl subjected to ukuthwala can lay a charge of abduction, rape and human
trafficking. 22 Family law also states that a girl-child subjected to ukuthwala has the
right to have the marriage annulled and also claim maintenance where appropriate,”
(justice.gov.za). 23

In 2015 the South African Law Reform Commission (SALRC) released a revised
discussion paper on the practice of ukuthwala; which included the proposed
Prohibition of Forced Marriages and Child Marriages Bill (Prohibition Bill). 24 The Bill
aims to criminalise forced and child marriage to anyone found guilty of child marriage
including ukuthwala. On reporting on the proposed Prohibition Bill, Warn bene and
Mqidlana note that the Bill makes ukuthwala a criminal offence if: 25
• The perpetrator applies violence or any form of aggression to force another
person to enter into a marriage.

17 Rampete N, Department of Justice and Constitutional Development

‘Ukuthwala’ < https://www.justice.gov.za/brochure/ukuthwala /ukuthwala.html >
accessed 20 March 2023
18 Department of Justice
19 The Constitution
20 The Children’s Act
21 Department of Justice
22 Department of Justice
23 Department of Justice
24 South African Law Reform Commission Reports Revised Discussion Paper 138 Project
138 The Practice of ukuthwala <https://www.justice.gov.za/salrc/dpapers/dp132-
ukuthwala revised.pdf> accessed 20 March 2023
25 Warn bene and Mqidlana, Should South Africa Criminalise Ukuthwala Leading to Forced
Marriages and Child Marriages? < http://www.scielo.org.za/scielo.php?
script=sci_arttext&pid=S1727-37812021000100052#top_fn14 > accessed May 2023

8
 • Leads the victim to believes that the conduct may cause them to enter into the
marriage without consent.
• The victim lacks the mental capacity to enter into a consensual marriage.

There are also compelling arguments presented by scholars that traditional leaders
are of the opinion that ukuthwala is a cultural practise that should be preserved. The
researcher agrees with the view that for ukuthwala to thrive and retain respect, there
ought to be proper education aimed at boys and traditional leaders on basic
understanding of human rights which automatically includes respect for women.
Jokani et al believe this “will go a long way to create a human rights culture in which
ukuthwala can still be practised with the consent of the girl and her family” 26

By authorizing the legal marriage age to 18 y/o under the Customary Marriages Act,27
it can be argued that South Africa has” outlawed customary marriages of children
under the age of 18 y/o “(Mwambene). 28 On the contrary, Mwambane further cautions
that” the Customary Marriages Act, read with the Marriage Act, allows persons below
the age of 18 to get married provided they have the necessary consent” (Mwambane).
29 Our law also provides that sex with a minor, which is a child below 16 y/o is a criminal
offense in terms of the Sexual Offences Act. 30 When analysed together, all the above-
mentioned laws present an obvious conflict against each other, against sexual
offences and against the efforts to end child marriages.

As noted by various human rights scholars, the researcher agrees that ukuthwala is
not only in conflict with existing laws such as the rights of the child, including their right
31
to education and protection from harm (Journal of African Law) but it is misogynistic,

26 Jokani et al ’A criminal law response to the harmful practices of ukuthwala’

< https://journals.co.za/doi/pdf/10.10520/EJC-14878650d1 > accessed June 2023
27 Customary Marriages Act
28 Mwambane Child marriage
29 Mwambane Child marriage
30 Sexual Offences Act
31 Journal of African Law, ’ Ukuthwala in South
Africa’ https://www.cambridge.org/core/journals/journal-of-african-law/listing?
q=UKUTHWALA+and+child+marriage+in+south+africa%3A+examining+the+divide+betw
een+custom+and+human+rights&searchWithinIds=7457CC9ABA67940F4E4B4B097765
8B2&fts=no > accessed 20 March 2023

9
and it shields paedophiles under the guise of culture. More importantly, it is a heinous
32
crime and a serious violation of human rights. Section 31 of the Constitution
recognises cultural rights of communities and groups provided that such rights are not
exercised in a manner inconsistent with any of the provisions of the Bill of Rights
(justice.gov.za). 33

CONCEPTUALISATION OF CENTRAL RESEARCH THEMES

The Constitution and Bill of Rights: The Constitution provides the legal foundation
for the existence of South Africa and in relation to how the country is governed. While
the Bill of enshrines the rights of all people in South Africa, no other law can supersede
the provisions of the Constitution. 34

Child bride: For the purpose of this research and as interpreted in the Constitution,
the word child is defined as any person under the age of 18 years. 35

Law (and the law): The Oxford English dictionary defines law as a system of rules
and the law is the universal system of rules that everyone in a country or society must
obey. 36

Ukuthwala: This is a form of abduction that involves kidnapping a girl or a young

woman by a man and his friends or peers with the intention of compelling the girl or
young woman's family to endorse marriage negotiations. 37

Child Justice: Various initiatives that allows the child's best interest to be taken into
consideration. 38

PROPOSED CHAPTER OUTLAY

32 The Constitution
33 Department of Justice
34 Department of Justice <http://www.justice.gov.za> accessed 23 March 2023
35 The Constitution
36 Oxford Learner’s Dictionaries
<https://www.oxfordlearnersdictionaries.com/definition/american_english/law> accessed
March 2023
37 Department of Justice
38 Department of Justice ’Child Justice’
< https://www.justice.gov.za/vg/childjustice.html#:~:text=The%20Child%20Justice%20Act
%20allows,to%20deal%20with%20the%20child > accessed May 2023

10
This research will be laid out as follows:

Chapter 1 This chapter will contain terms and concepts central to the research
problem. It will also concentrate on the introduction of the research topic,
researcher’s hypothesis and further outlines the methodology of the
research product.
Chapter 2 Critical analysis of the historical development of all applicable legislation
pertaining to child marriages and children’s rights such as the
Constitution, Bill of Rights, Children’s Act, Sexual Offences and Related
Matters Act, and Family Law. This will also take into consideration,
relevant case law that led to the development of these laws.

Chapter 3 This chapter will analyse the legal framework pertaining to the protection
of women and children’s rights against harmful cultural practices such as
ukuthwala in South Africa, including constitutional rights relevant to
Customary Law and the practice of ukuthwala.

Chapter 4 This chapter will provide conclusions to summarise the research and will
provide recommendations to support arguments presented in the
research.

PROJECTED TIME FRAME FOR SUBMISSION

The intention of this research is to submit the research product per the timeline
provided below:

CHAPTER EXPECTED DATE OF SUBMISSION

Submit draft research proposal 13 April 2023

Receive draft proposal with comment 13 May 2023

Resubmit corrected research proposal 20 May 2023

Submit chapter 1 13 June 2023

Submit chapter 2 13 July 2023

Submit chapter 3 13 August 2023

11
 Submit chapter 4 13 September 2023

Revise and resubmit chapter 1 – 4 13 October 2023

Final submission for examination 13 November 2023

DESCRIPTION OF PROPOSED RESEARCH METHODOLOGY

This research will make use of a historical approach to trace the development of South
Africa’s child law. We will apply an investigative comparison into the culture of
ukuthwala so as to highlight notable conflicts with the Constitution of South Africa. The
research will also explore any other legislative amendments South Africa has passed
to rectify the psychological impact of ukuthwala and child marriages, such as the
Domestic Violence Act. Focus will be on both primary and secondary resources such
as legislation, website pages, case law, journal articles and academic writings. The
time period researched is 1996 - 2023.

12
CONCLUSION

It is obvious that children should be afforded special treatment due to their vulnerability
and lack of maturity. We often sentimentalize that Africa is rich with natural resources
and still the poorest of the poor. Yet we seem to forget that much of Africa’s suffering
is now self-inflicted, that “a community’s development depends on its people, which
includes the level of health, knowledge and education controlled by those people.
Since ukuthwala undermines the girl-child’s access to these opportunities, it
subsequently undermines the country’s development” (justice.gov.za). 39 As indicated
in the statistics and research above, harmful cultural traditions that violate human
rights and the legal system are unsuited for children and its society, and the techniques
employed do not facilitate the establishment of the truth. From an administrative point
of view, much has been done. Constitutional developments have introduced an
approach to children that recognizes their vulnerability and recognize that children be
treated with dignity and compassion. However, there is a clear conflict between the
rights of children and women as afforded by the constitution and the Recognition of
Customary Law Marriages Act which permits ukuthwala. This is partly due to the fact
that efforts put in place by the South African government such as the amendment of
various legislation to prevent harmful cultural practices is often perceived by traditional
leaders and communities as a violation of traditions and values.

Since the biggest challenge is in the implementation of government policies to ensure

cultural practises do not violate human rights. The research recommends that a
suitable response to this challenge is to legislate the requirement for courts to deal
with ukuthwala perpetrators by applying existing common law and legislative
instruments. It is obvious that certain elements of ukuthwala cannot be justified in a
democratic South Africa, therefore, there needs to be a concerted effort in customary
law reform to include certain aspects of ukuthwala as a serious schedule 8 criminal
offence which includes sexual offences, human trafficking and more; and anyone
found guilty of this crime will be severely punished. It is also the researcher’s view that
the Recognition of Customary Law Marriages Act should criminalise child marriage so
it’s in line with the provisions of The Children’s Act 38 of 2005, which emphasizes the
prevention of child marriages.5 In the famous words of Nelson Mandela, “our children

39 Department of Justice

13
are our greatest treasure. Freedom cannot be achieved unless women and children
have been emancipated from all forms of oppression” (Mandela, 1994) 40

BIBLIOGRAPHY

Legislation

Children’s Act 38 2005

Child Justice Act 75 of 2008 (CJA)

Domestic Violence Act 116 of 1998

Customary Marriages Act

Recognition of Customary Marriages Act 120 of 1998

Sexual Offences Act

Family Law and Sexual Offences and Related Matters Act 23 of 1957

The Constitution
The Constitution of the Republic of South Africa, 1996

Case Law

Jezile v. S and Others (A 127/2014) 2015 ZAWCHC

Books

Botha Statutory Interpretation 5.

Botha C Statutory Interpretation: An Introduction for Students (Juta 2005) 5.

Currie, de Wall Bill of Rights 6.

Currie I and de Waal J, The Bill of Rights Handbook (Juta 2005) 6.

Internet

African Union, ‘End Child Marriage’

African Union Campaign to End Child Marriage was launched in 2014

https://au.int/en/sa/cecm (Date of use: 16 May 2023)

40 Nelson Mandela Foundation, ‘Nelson Mandela and women's rights’ <

https://www.nelsonmandela.org/acom-blog/archive-nelson-mandela-and-womens-
rights#:~:text=Nelson%20Mandela%20was%20a%20champion,from%20all%20forms%20of%
20oppression%E2%80%9D> accessed 02 April 2023

14
Department of Justice, ’Child Justice’

Department of Justice and Constitutional Development ’Child Justice’

https://www.justice.gov.za/vg/childjustice.html#:~:text=The%20Child%20Justice%20Act%20al
lows,to%20deal%20with%20the%20child (Date of use: 20 May 2023)

Girls Not Brides

Girls Not Brides is a global partnership of more than 1600 organisations in over 100 countries
committed to ending child marriages around the world https://www.girlsnotbrides.org Date of
use: 01 June 2023

Journal of African Law, ‘Ukuthwala and Child Marriage in South Africa’

Journal of African Law ‘Ukuthwala and Child Marriage in South Africa

https://www.cambridge.org/core/journals/journal-of-african-law/listing
q=UKUTHWALA+and+child+marriage+in+south+africa%3A+examining+the+divide+between
+custom+and+human+rights&searchWithinIds=7457CC9ABA67940F4E4B4B09776518B2&ft
s=no (Date of use: 20 March 2023)

Mwambene ‘Recent legal responses to child marriage in Southern Africa’

Mwambene L, ‘Recent legal responses to child marriage in Southern Africa: The case of
Zimbabwe, South Africa and Malawi’ http://www.scielo.org.za/scielo.php (Date of use: 16 May
2023)

Nelson Mandela Foundation, ‘Nelson Mandela and women's rights’

https://www.nelsonmandela.org/acom-blog/archive-nelson-mandela-and-womens-
rights#:~:text=Nelson%20Mandela%20was%20a%20champion,from%20all%20forms%20of%20oppr
ession%E2%80%9D (Date of use: 02 April 2023)

Oxford Learner’s Dictionaries

https://www.oxfordlearnersdictionaries.com/definition/american_english/law Date of use: 23 March
2023

Rampete ‘Ukuthwala’

Rampete N, Department of Justice and Constitutional Development ‘Ukuthwala’

< https://www.justice.gov.za/brochure/ukuthwala /ukuthwala.html > accessed 20 March 2023

Jezile v. S and Others

SAFLII ‘Jezile v. S and Others (A 127/2014) 2015 ZAWCHC

http://www.saflii.org/za/cases/ZAWCHC/2015/31.html Date of use: 22 March 2023

Jokani et al ’A criminal law response to the harmful practices of ukuthwala’

Jokani et al ’ A criminal law response to the harmful practices of ukuthwala’

https://journals.co.za/doi/pdf/10.10520/EJC-14878650d1 Date of use: June 2023

SALC Issue paper on The Practice of ukuthwala

South African Law Reform Commission Reports Revised Discussion Paper 138 Project 138
The Practice of ukuthwala https://www.justice.gov.za/salrc/dpapers/dp132-ukuthwala
revised.pdf Date of use: 20 March 2023

15
Statista ‘highest absolute numbers of child marriages as of 2020
https://www.statista.com/statistics/1228332/highest-absolute-number-of-girl-brides-by-country/ Date
of use: 20 March 2023

UNICEF, ‘A Profile of Child Marriage in Africa’

UNICEF, ‘A Profile of Child Marriage in Africa’ tps://data.unicef.org/resources/a- profile-of-

child-marriage-in-africa/ (Date of use: 01 June 2023)

UNICEF ‘Child marriage threatens the lives, well-being, and futures of girls around the world’

UNICEF ‘Child marriage threatens the lives, well-being, and futures of girls around
the world’ https://www.unicef.org/protection/child-marriage Date of use: 20 March 2023

16