MOKGORO J [82] In my view the importance of providing access to social assistance to all who live permanently in South Africa and the impact upon life and dignity that a denial of such access has, far outweighs the financial and immigration considerations on which the state relies. For the same reasons, I am satisfied that the denial of access to social grants to permanent residents who, but for their citizenship, would qualify for such assistance does not constitute a reasonable legislative measure as contemplated by section 27(2) of the Constitution. [83] There is a difficulty in applying section 36 of the Constitution to the socio-economic rights entrenched in sections 26 and 27 of the Constitution. Sections 26 and 27 contain internal limitations which qualify the rights. The state’s obligation in respect of these rights goes no further than to take “reasonable legislative and other measures within its available resources to achieve the progressive realisation” of the rights. If a legislative measure taken by the state to meet this obligation fails to pass the requirement of reasonableness for the purposes of sections 26 and 27, section 36 can only have relevance if what is “reasonable” for the purposes of that section, is different to what is “reasonable” for the purposes of sections 26 and 27. [84] This raises an issue which has been the subject of academic debate but which has not as yet been considered by this Court.85 We heard no argument 85 See Van der Walt The Constitutional Property Clause (Juta, 1997) 92-5; Rautenbach General Provisions of the South African Bill of Rights (Butterworths, 1995) 84-5 and 106-07; De Waal et al The 51