Important statistics proving the vulnerability of women and domestic workers, in general, were also presented. Issues for Determination 13. The following are the issues that this Court has been invited to determine: 13.1 whether the 2nd Claimant, the Registered Trustees of Domestic and Vulnerable Workers Association (DOVWA): i. has sufficient locus standi in the matter; and ii. can maintain an action or invoke representative standing on behalf of domestic workers; 13.2 whether section 11 of the Pension Act which gives powers to the Minister to exempt any class or category of employers and employees from complying with the requirements of the mandatory occupational pension scheme is unconstitutional; 13.3 whether the inclusion of domestic workers in the Minister’s Pension (Exemptions) Order, 2025 made pursuant to section 11 of the Pension Act is unconstitutional on the ground that it infringes upon the rights of domestic workers under sections 13, 20, 30(3) and 31(1) of the Constitution; Page 7 of 45