A/HRC/17/33/Add.4 32. The Special Rapporteur also noted that the above policies have not led to an increase in the overall volume of migration from Zimbabwe to South Africa. Of the range of legal policy options available to regularize movement between Zimbabwe and South Africa, the proposed special dispensation permit is the most appropriate to the context (the need of Zimbabweans to work and to move freely between countries), besides being the easiest to implement. 33. As the Special Rapporteur was able to see first-hand, many Zimbabweans move frequently between the two countries, often to buy and resell food and goods to support their families remaining in Zimbabwe. Large segments of the Zimbabwean population and economy have been supported for years through remittances from South Africa. Such transfers have been beneficial in supporting the most vulnerable women, children and elderly persons left behind in Zimbabwe. 34. The Special Rapporteur is of the opinion that the special dispensation permits are more likely to facilitate the return of Zimbabweans home than provide an incentive to remain in South Africa, because people can return to Zimbabwe for short periods to assess the stability and economic opportunities of the country without fearing to lose their ability to earn a livelihood in South Africa. There is evidence that migrants who feel threatened through deportation and a lack of legal options for movement are more likely to stay in a foreign country, despite the extreme hardships, since return without alternatives for a known livelihood is too risky. Furthermore, they can gradually invest the money earned in South Africa to re-establish themselves and develop a livelihood in Zimbabwe. V. Major challenges in the protection of the human rights of migrants 35. Despite the positive measures recently taken at the national level, the Special Rapporteur found that challenges are still to be addressed by the Government, particularly that of effectively protecting the human rights of migrants. A. Absence of a clear and comprehensive immigration policy 36. Although South Africa is part of the SADC Protocol on the Facilitation of the Movement of Persons, the Special Rapporteur noted the absence of an institutional strategy for this region on migration. 37. South Africa is an attractive destination for Africans from all over the continent, lured by work in mines, farms and homes. Although there are no exact figures available, the Government often cites an estimate of between 4 and 8 million immigrants in the country at any given time. Statistical sources suggest that about 1.5 million of these are Zimbabwean nationals.6 38. The Special Rapporteur believes that a clear and comprehensive immigration policy is necessary. Although he was pleased to note that some measures to manage migration flows have been taken, they mostly affect Zimbabwean nationals, who currently represent the largest group of migrants residing in South Africa. 39. The Special Rapporteur did, however, note certain flaws in the above initiative. Permits are issued under the Immigration Act and allow Zimbabwean nationals to apply for 6 10 Regularising Zimbabwean Migration to South Africa, Migration Policy Brief, Consortium for Refugees and Migrants in South Africa, May 2009.