The right to development is entrenched in Africa-based international human rights instruments. Yet, the majority of African people suffer great indignity due to poverty occasioned by inequality and disempowerment. The group most affected are women and their vulnerability is further exacerbated where the majority of them do not enjoy substantive citizenship. Substantive citizenship presupposes that they (women) are active participants towards their own socio-economic development through the elimination of discriminatory laws that adversely affect them. Socio-economic development can only be protected where women have legal claims to the entitlements that arise from national recognition and identity. We argue in this article that the basis therefore, for holding governments accountable for the duty to promote the right to development starts with citizenship rights. Where citizenship rights are compromised, development in social, economic, political and cultural spheres remains an illusion.