through the textual hook of a limitations clause, 27 South Africa does not lack this feature. 28 Yet the Constitutional Court has spearheaded a very different approach for economic and social rights adjudication, which now garners significant worldwide influence.29 In the duly famed Grootboom decision,30 the first successful case under the constitutional guarantee of a right to housing, the South African Constitutional Court adopted, with attention to constitutional text,31 a particular standard for reviewing economic and social rights cases – the approach known as “reasonableness review”.32 This approach engages a means-end inquiry, but in a version distinctly more searching than mere “rationality review”.33 Like proportionality analysis, reasonableness review presses for a justification, in order to enhance the accountability of official decision makers and the transparency of their decisions. But it would be a mistake to see this test as merely the first two (or even 27 Mattias Kumm, The Idea of Socratic Contestation and the Right to Justification: The Point of RightsBased Proportionality Review, 4 L. & ETHICS HUM. RTS. 140 (2010). 28 Sth Afr. Const. § 36. The rights in the Bill of Rights may be limited only in terms of law of general application to the extent that the limitation is reasonable and justifiable in an open and democratic society based on human dignity, equality and freedom, taking into account all relevant factors, including— (a) the nature of the right; (b) the importance of the purpose of the limitation; (c) the nature and extent of the limitation; (d) the relation between the limitation and its purpose; and (e) less restrictive means to achieve the purpose. 29 See infra note 122 and accompanying text. 30 Government of the Republic of South Africa v Grootboom 2001 (1) SA 46 (CC) (S. Afr.) (‘Grootboom’). 31 Sth. Afr. Const., § 26(2) (“The state must take reasonable legislative and other measures, within its available resources, to achieve the progressive realisation of this right” for housing); see also § 27(2) (reasonable measures for healthcare, food, water and social security), § 29(1)(b) (reasonable measures for further education). 32 For an extensive presentation and assessment of reasonableness review, see SANDRA LIEBENBERG, SOCIO-ECONOMIC RIGHTS: ADJUDICATION UNDER A TRANSFORMATIVE CONSTITUTION 141 (2010). 33 See Geo Quinot and Sandra Liebenberg, Narrowing the Band: Reasonableness Review in Administrative Justice and Socio-Economic Rights Jurisprudence in South Africa, in LAW AND POVERTY (Sandra Liebenberg & Geo Quinot, eds., 2012) 197. 6