VOLUME1 1 They must, however, ensure that the measures they adopt are reasonable. In any challenge based on section 26 in which it is argued that the state has failed to meet the positive obligations imposed upon it by section 26(2), the question will be whether the legislative and other measures taken by the state are reasonable. A court considering reasonableness will not enquire whether other more desirable or favorable (sic) measures could have been adopted, or whether public money could have been better spent. The question would be whether the measures that have been adopted are reasonable. It is necessary to recognize (sic) that a wide range of possible measures could be adopted by the state to meet its obligations. Many of these would meet the requirement of reasonableness. Once it is shown that the measures do so, this requirement is met.49 The state policies to implement economic and social rights must be reasonable, according to the jurisprudence of the South-African Court of Human Rights. However, this approach also has quite a few disadvantages, one of the most prominent is the non-transparency of reasons for state policy, which could be deemed as reasonable, and another is the reverse burden of proof, which creates difficulties in showing that the state policy was unreasonable. 50 Therefore, the combination of both approaches can overcome their deficiencies. Yeshanew observes that the minimum core model, "more or less concentrates on the content of the rights to identify minimum obligations," the reasonableness test, "focuses on the obligations of states or measures to realize rights." 5' The two-tiered approach can effectively address the deficiencies of both approaches. In the same way, courts and human rights bodies can apply such approach towards negative and positive obligations under social and economic rights. 52 The concept of the minimum core identifies minimum core obligations to respect, protect, and fulfil economic and social rights. It has been illustrated that economic crises often affect the ability of a state to even comply with 3 this minimum core obligation to provide economic and social rights.1 continued to review its policy regularly and undertaken sophisticated research to seek to ensure that it meets the needs of the poor within the city. It cannot therefore be said that the policy adopted by the City was inflexible, and the applicants' argument on this score too must fail" (para. 97). See also Nokotyana v. Ekurhuleni Metropolitan, 2009 (4) BCLR 312 (CC) (S. Afr.); see also Etienne Mureinik, Beyond a Charter of Luxuries: Economic Rights in the Constitution, 8 SAJHR 464, (1992). 49 Grootboom, SA 46 (CC) Para. 41. 50Yeshanew, supra note 36, at 289-290. id. at 294. 52 Id. 53 See SOVEREIGN FINANCING AND INTERNATIONAL LAW, THE UNCTAD PRINCIPLES ON RESPONSIBLE SOVEREIGN LENDING AND BORROWING (Carlos Esp6sito et al. eds., 2013).

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