differences between the decisions cited by the Constitutional Court and the case in hand Hewlett dealt with a law that cancelled an existing state debt to an individual; Davies concerned a law that >designates= certain land for possible future expropriation for purposes of land reform; and Harksen involved the vesting of a solvent spouse =s property to prevent fraudulent dealings to the detriment of innocent cred itors. It does not take an overactive imagination to see that the three ituations differ in what must surely be essential characteristics. a truly contextual interpretation of any constitutional expropriation provision must take note of and account for these differences between cases. This makes it necessary to consider the comparative authority of similar- looking cases very carefully: in actual fact the davies case should not even be mentioned in the sam breath as the Hew lett case, even though both are decisions of the Zimbabwe Supreme Court Both provide authority for the valid ity of the distinction between deprivations and expropriations, but Davies dealt with regulations that notify the state=s intention to consider the expropriation of the property in future, without acquiring any rights in it for the time being In Hewlett the law question cancelled a state debt, thereby destroy ing the cred itor=s right to claim the debt and relieving the state of the duty to pay. The statement that a certain state action does not constitute an expropriation because it does not cause the state to acquire any rights in the property is perfectly acceptable in the context of Davies, but it simply makes no sense in the context of either Hewlett or Harksen. To take the point one step further: the more recent Zimbabwean decision in Chairman. Public Service Commission and Others y Zimbabwe Teachers Association and Othersshould also be distinguished carefully from Hew lett, although both dealt with money debts. In Teachers= Association the ratio decidendi was not>(as in Hew lett) that a cancellation of a state debt does not constitute an acquisition and therefore also not an expropriation, but rather that the debt in question(teachers= annual bonus) was not a vested right and that the law in question could therefore amend or abolish the annual bonus without thereby affecting an existing property right A part from ignoring the differences between various kinds of property, the reasoning of the Harksen court(and the Zimbabwean Supreme Court in the cases referred to) is too simplistic in its analysis of the effects of the regulation concerned. Although there is no clear approach in case law,3a comparative analysis suggests that, as far as constitutional property guarantees are concerned, the scope of the term >expropriation= or >compulsory acquisition= cannot simply be restricted to physical dispossessions or actual acquisitions by the state b the distinction between deprivations and expropriations is clearly more complex than that. More particularly, there are instances, especially in the range of intangible property rights, where a complete destruction of a property right by the state could arguably be regarded as an expropriation even though the High Court )and has no real constitutional authority or interest. The case concerned the expropriation of water servitudes in terms of the Water Act 54 of 1956.s 94 1997(1)SA209(ZSC. Although the court is not at all clear about this, statements conceming the question of acquisition confuse the issue considerably ome of the relevant cases are d iscussed later in this article9 differences between the decisions cited by the Constitutional Court and the case in hand: Hewlett dealt with a law that cancelled an existing state debt to an individual; Davies concerned a law that >designates= certain land for possible future expropriation for purposes of land reform; and Harksen involved the vesting of a solvent spouse=s property to prevent fraudulent dealings to the detriment of innocent creditors. It does not take an overactive imagination to see that the three situations differ in what must surely be essential characteristics. A truly contextual interpretation of any constitutional expropriation provision must take note of and account for these differences between cases. This makes it necessary to consider the comparative authority of similar-looking cases very carefully: in actual fact, the Davies case should not even be mentioned in the same breath as the Hewlett case, even though both are decisions of the Zimbabwe Supreme Court. Both provide authority for the validity of the distinction between deprivations and expropriations, but Davies dealt with regulations that notify the state=s intention to consider the expropriation of the property in future, without acquiring any rights in it for the time being. In Hewlett the law in question cancelled a state debt, thereby destroying the creditor=s right to claim the debt and relieving the state of the duty to pay. The statement that a certain state action does not constitute an expropriation because it does not cause the state to acquire any rights in the property is perfectly acceptable in the context of Davies, but it simply makes no sense in the context of either Hewlett or Harksen. To take the point one step further: the more recent Zimbabwean decision in Chairman, Public Service Commission and Others v Zimbabwe Teachers= Association and Others35 should also be distinguished carefully from Hewlett, although both dealt with money debts. In Teachers= Association the ratio decidendi was not36 (as in Hewlett) that a cancellation of a state debt does not constitute an acquisition and therefore also not an expropriation, but rather that the debt in question (teachers= annual bonus) was not a vested right and that the law in question could therefore amend or abolish the annual bonus without thereby affecting an existing property right. Apart from ignoring the differences between various kinds of property, the reasoning of the Harksen court (and the Zimbabwean Supreme Court in the cases referred to) is too simplistic in its analysis of the effects of the regulation concerned. Although there is no clear approach in case law,37 a comparative analysis suggests that, as far as constitutional property guarantees are concerned, the scope of the term >expropriation= or >compulsory acquisition= cannot simply be restricted to physical dispossessions or actual acquisitions by the state B the distinction between deprivations and expropriations is clearly more complex than that. More particularly, there are instances, especially in the range of intangible property rights, where a complete destruction of a property right by the state could arguably be regarded as an expropriation even though the High Court) and has no real constitutional authority or interest. The case concerned the expropriation of water servitudes in terms of the Water Act 54 of 1956, s 94. 35 1997 (1) SA 209 (ZSC). 36 Although the court is not at all clear about this; statements concerning the question of acquisition confuse the issue considerably. 37 Some of the relevant cases are discussed later in this article