Under pre-independence customary law, women’s access to land was primarily through their husbands, fathers or some other male relative. Under the Communal Land Reform Act of 2002, there are no bars to gender equality in the allocation of communal land - but there is no direct articulation ofthe principle of non-discrimination, nor any affirmative action for women. Land continues to be allocated by traditional leaders, with the allocations being ratified by community land boards, about one third of whose members should be women.