relevant standard, could guide its assessment of reasonableness.61 Arguably, a compelled attention to the needs of the most vulnerable fosters the same attitude of priority-setting as the minimum core inquiry, without “entrenching” the judiciary’s own articulation of what the minimum core demands. Instead, an approach inflected with a focus on the experience of vulnerability (and what I shall describe as the inflection of proportionality), is provided. Before moving to describe this standard in Part III, I will outline the features of the proportionality analysis that has been influential in constitutional rights adjudication elsewhere. II. PROPORTIONALITY ANALYSIS Like reasonableness review, proportionality analysis provides a contextual standard for the judicial safeguarding of constitutional rights. Indeed, proportionality may be understood to be a subset of reasonableness – it has been counted among the leading manifestations of reasonableness in public law.62 For example, the rationality behind the means-end analysis of an official decision or statute, that is part of the reasonableness inquiry, could not sustain a grossly disproportionate result.63 Nonetheless, it is said to be proportionality analysis, rather than the principle of proportionality and its connection to 61 Grootboom 2001 (1) SA 46 (CC), paras 31-33; See also Minister of Health v. Treatment Action Campaign 2002 (5) SA 721 (CC), paras 34-39. 62 W. Sadurski, Reasonableness and Value Pluralism in Law and Politics, in REASONABLENESS AND LAW 129, 133-4 (Giorgio Bongiovanni et al. eds., 2009); Iddo Porat, Some Critical Thoughts on Proportionality, in REASONABLENESS AND LAW. This volume shows a series of differing views on this relationship. 63 AHARON BARAK, PROPORTIONALITY: CONSTITUTIONAL RIGHTS AND THEIR LIMITATIONS 371–78 (2012) (noting how “the marginal social importance of the benefits gained by achieving the law’s purpose have to be evaluated against the marginal social importance of preventing the harm caused to a constitutional right”). 12