thus linking the two analyses, 97 in ways that may be less immediately obvious in proportionality analysis. The divergence on the two approaches to interpreting the right becomes less sharp if one recognizes economic and social rights as principles, and there is nothing within the reasonableness assessment that prevents an open and broad statement of content before proceeding to the reasonableness inquiry. Nonetheless, the omission of this step has consequences for its placement of the burden of proof in rights adjudication. As a general matter, it is for the applicant to establish the breach of a fundamental right. Under proportionality analysis, the burden then shifts to the government to justify its prima facie infringement of the relevant right;98 in reasonableness review, it may remain with the claimant, a not-insignificant barrier.99 These differing approaches to content are also distinct in relation to the minimum core idea. Certainly, reasonableness review may accommodate conceptions of a minimum threshold as one in a series of criteria that the Court will consider.100 In contrast, the effect of the minimum core on the exercise of proportionality analysis is to minimize the right at both stages of the inquiry: in forming content and in justifying limitations. 97 For the importance of linking review with remedy, see Katharine G. Young, A Typology of Economic and Social Rights Adjudication, 8 INT’L J. CONST. L. 1 (2011). 98 S v. Makwanyane, 1995 (3) SA 391, para 6; see also Woolman & Botha, supra note 87, 34.6. 99 The degree to which this burden extends across §§ 26(2) and 27(2) is uncertain. See the analysis of Sandra Liebenberg, Interpretation of Socio-Economic Rights, in CONSTITUTIONAL LAW OF SOUTH AFRICA (2nd ed, OS, December 2003), 33-53 (suggesting that “the party claiming a constitutional violation would have to establish a prima facie case that the measures undertaken are unreasonable” but that “[i]f the state wishes to rely on a lack of available resources … it should bear the burden of proving the alleged unavailability of resources”). 100 Treatment Action Campaign 2002 (5) SA 721 (CC). 23