MOKGORO J Main contentions of the parties [38] The applicants contended that the exclusion of all non-citizens from the scheme is inconsistent with the state’s obligations under section 27(1)(c) of the Constitution to provide access to social security to “everyone”. The relevant parts of section 27 of the Constitution provide: “Health care, food, water and social security — (1) Everyone has the right to have access to — ... (c) social security, including, if they are unable to support themselves and their dependants, appropriate social assistance. (2) The state must take reasonable legislative and other measures, within its available resources, to achieve the progressive realisation of each of these rights.” [39] They also argued that the exclusion limited their right to equality and was unfair under section 9 of the Constitution and that the limitation was unjustifiable under section 36 of the Constitution. They further contended that their right to life under section 11 of the Constitution and their right to dignity under section 10 were infringed without justification. In so far as the grants in favour of children were concerned, they contended that the exclusion also infringed the rights that children have under section 28 of the Constitution. The respondents essentially advanced reasons that motivated and, so it was submitted, justified the decision to exclude all non-citizens, including 26