of achieving a statistical advance in the realisation of the right. Furthermore, the Constitution requires that everyone be treated with care and concern.49 This standard of reasonableness requires, then, all sectors to be catered for in any given policy directed to housing, health care, food, water, social security, or education, including the most vulnerable.50 Due to the Constitutional Court’s attention to those in “crisis” situations,51 some have suggested that the standard requires a short-term, as well as long-term, policy approach.52 Others have pointed to the focus on the values of dignity and equality undergirding reasonableness review in relation to economic and social rights.53 But it is the focus on the needs of the most vulnerable that links the approach to a conception of constitutional rights with due attention to those “whose needs are most urgent”54 that directs our inquiry into its relationship with proportionality. The target of this analysis is not the “discrete and insular minorities” 55 worthy of constitutional rights protection in the prominent U.S. model, which is based on a democratic justification of groups disproportionality underrepresented in political 49 Grootboom 2001 (1) SA 46 (CC), para 44. Roux, supra note 43. 51 Grootboom 2001 (1) SA 46 (CC) at para. 43, 74. 52 Wesson, supra note 44; cf. Roux, supra note 43 (no temporal priority). See also Grootboom 2001 (1) SA 46 (CC) at para 43 (holding that a program must “make appropriate provision for attention to housing crises and to short, medium and long term needs”). 53 Carol Steinberg, Can Reasonableness Protect the Poor? A Review of South Africa’s Rights Jurisprudence, 123 S. AFR. L.J. 264 (2006). 54 Grootboom 2001 (1) SA 46 (CC) (S. Afr.). See also City of Johannesburg Metropolitan Municipality v Blue Moonlight Properties 39 (Pty) Ltd 2012 (2) SA 104 (CC) (concerning the rights of people in desperate need of housing who are subject to eviction from land by private landowners.). 55 U.S. v. Carolene Products, 304 US 144 (1938) (Justice Stone justifying “strict scrutiny” in cases in which legislation appears to be directed at ‘discrete and insular’ minorities, or groups of people who have historically been marginalised and subjected to prejudice.) 50 10