Do I need separate wills for my UK and Zimbabwe assets?

If you live in the UK but own property or other assets in Zimbabwe, a single UK will is often not enough to protect your estate. Most countries, including Zimbabwe, apply the principle of lex situs — meaning the law of the country where an asset is physically located generally governs what happens to it when you die, regardless of what a will written elsewhere says. Zimbabwean law does allow a will to cover a worldwide estate, and the Supreme Court case Rogers v Rogers and Another 2008 (1) ZLR 330 (S) confirmed that a testator can instead choose to hold separate wills for assets in different jurisdictions. Section 22(4) of Zimbabwe's Wills Act goes further for immovable property specifically: a will covering Zimbabwean land or a house is formally valid as long as it complies with Zimbabwean law, no matter where in the world it was signed. This gives diaspora Zimbabweans flexibility, but it also means a UK will drafted only with English and Welsh formalities in mind may not smoothly transfer Zimbabwean property without separate legal attention. The practical guidance from legal sources on both sides is consistent: have two wills, one covering your UK estate under English and Welsh law, and a separate one covering your Zimbabwean estate, drafted and executed to meet Zimbabwean requirements. Each will should clearly state that it only deals with assets in its own jurisdiction, and the two documents must reference each other carefully so that neither accidentally revokes the other. Keep both wills updated whenever your assets or family circumstances change. For your Zimbabwean estate, your Zimbabwean property cannot be inherited until an executor is legally recognised in Zimbabwe, which is a separate process from UK probate and can be delayed significantly if you have not planned for it. Appointing a Zimbabwean conveyancer or legal practitioner through a registered Power of Attorney can help your chosen representative act on your behalf during this process. Given the complexity, instruct a qualified lawyer in Zimbabwe to draft your Zimbabwean will and a UK will writer or solicitor for your UK estate, and ask both to coordinate so your family is not left to untangle conflicting documents during an already difficult time. Sources: https://www.propzone.co.zw/en/knowledge-base/legal-finance/how-to-write-valid-will-zimbabwe-wills-act-requirements, https://octopuslegacy.com/advice/if-you-own-property-abroad-your-uk-will-may-not-be-enough, https://www.propzone.co.zw/en/knowledge-base/legal-finance/zimbabwean-property-inheritance-diaspora-death-abroad, https://www.facebook.com/groups/760625214070465/posts/4055655304567423