Under reasonableness review, deference is bound up with the content inquiry, discussed above, where the right is given an interpretation generous to the government’s (or other actor’s) discretion. 104 Under proportionality analysis, on the other hand, deference is provided through the application of a margin of appreciation or discretion, particularly in order to deal with the threat of judicial usurpation represented by a “less restrictive means” analysis, as applied to positive obligations. For example, the cost savings of a measure restrictive of a right to health care, or housing, for example, may be viewed, without deference, as trivial by a court (and therefore not necessary) or as capable of being shifted or offset by other aspects of the budget (and therefore not the least restrictive means).105 Other cases susceptible to a “dollars versus rights” frame may push too closely on both epistemic and democracy based limitations. 106 Hence, the “selfrestraining reaction”107 of deference is triggered on the part of the court. And like other “containment” doctrines,108 the general posture of deference, or a margin of appreciation, immediately defeats the rigor (and consistency) of the inquiry in the first place. 104 E.g., Mazibuko 2010 (3) BCLR 239 (CC); and attendant criticisms, LIEBENBERG, supra note 32. Reasonableness review integrates discretion to lower courts, in, e.g., horizontal application inquiries, or even the epistemic discretion required for science: see, e.g., Treatment Action Campaign 2002 (5) SA 721 (CC). 105 See, e.g., the Canadian cases of Eldridge v. British Columbia (A-G) [1997] 3 SCR 624 and Gosselin v. Quebec (A.G.) [2002] 4 SCR 429 (dissent). For a recent acknowledgement that budgets will be within the purview of reasonableness analysis, see Blue Moonlight 2012 (2) SA 104 (CC) para 74 (Sth. Afr.) 106 E.g., Newfoundland (Treasury Board) v. N.A.P.E. [2004] 3 SCR 381. (Canadian Supreme Court passing through every stage of proportionality before finding that a burden on pay equity was justifiable in the context of a fiscal crisis). 107 Contiades & Fotiadou, supra note 21. 108 For a broader outline of “containment” doctrines, see Colm O’Cinneide, The Constitutionalization of Social and Economic Rights, in SOCIAL AND ECONOMIC RIGHTS IN THEORY AND PRACTICE 261 (Helena Alviar García et al. eds., 2015) (as designed to limit the “spillover” of civil and political rights protection and administrative law controls into the social and economic realm). 25