The Bill of Rights was incorporated into the Constitution of the United Republic of Tanzania (CURT) in 1984 through the Fifth Amendment to the Constitution. The enforcement of the Bill of Rights began in 1987 before the formulation of the formal procedural rules. The court began to handle human rights cases while there were no formal procedures in place. The case of Chumchua Marwa v. Officer of Musoma Prisons and the Attorney General marked the first case on the enforcement of the Bill of Rights (violations of human rights) heard by the High Court of Tanzania, as empowered by article 30(4) of the Constitution. Several reasons drove the government to embark on the business of incorporating the Bill of Rights into the Constitution. These include, among others, pressure from international organizations like the International Monetary Fund (IMF) through its structural adjustment policies (SAPs) as lending requirements from international financial institutions, pressure from human rights activists within Tanzania and the unilateral inclusion of the Bill of Rights in the Constitution of Zanzibar.