discretion opened up by rights adjudication and enforcement. If economic and social rights are part of that global model, a suggestion supported by recent empirical analysis,14 there are numerous sites on which to establish the proportionality analysis. And yet, the comparative constitutional practice around economic and social rights reveals little resembling proportionality analysis, otherwise so “ubiquitous”15 in constitutional rights adjudication. Instead, the adjudication of economic and social rights integrates notions of proportionality in a seemingly indirect faction, through giving substance to standards of “reasonableness”,16 “appropriate measures”,17 and “progressive realization … according to maximum available resources”.18 These standards share with proportionality analysis the rejection of more content-driven, results-oriented, or rule-like conceptions of economic and social rights, such as the minimum core.19 But that rejection alone does not answer the question how proportionality, whether as principle or structured approach, relates to these new standards, particularly to that of reasonableness, a standard that now sets the framework for previously-absent international scrutiny on economic and social 14 Courtney Jung, Ran Hirschl & Evan Rosevear, Economic and Social Rights in National Constitutions, 610 Am. J. Comp. L. 1043 (2014) (counting a full third of constitutions, mainly from Latin America and Eastern Europe, and mainly from civil law jurisdictions, with justiciable economic and social rights guarantees.) 15 MÖLLER, supra note 12. see Stephen Gardbaum, Positive and Horizontal Rights: Proportionality’s Next Frontier or A Bridge Too Far? in this collection. 16 Grootboom, see infra Part I. 17 UN Committee on Economic, Social and Cultural Rights, General Comment No. 9: The domestic application of the Covenant (UN doc. E/C.12/1998/24); Maastricht Guidelines on Violations of Economic, Social and Cultural Rights (later reissued as UN document E/C.12/2000/13); see further Olivier De Schutter, Editor's Introduction to ECONOMIC, SOCIAL AND CULTURAL RIGHTS AS HUMAN RIGHTS (Olivier De Schutter, ed., 2013). 18 ICESCR, art 2(1). 19 UN Committee on Economic, Social and Cultural Rights (CESCR), General Comment No. 3: The Nature of States Parties' Obligations, U.N. Doc. E/1991/23 (Dec. 14, 1990); see also Katharine G. Young, The Minimum Core of Economic and Social Rights: A Concept in Search of Content, 33 YALE J. INT’L L. 113 (2008). 3