MOKGORO J grants in question, is not reasonable. Besides, it is doubtful whether the need for a social grant will be viewed as an “exceptional circumstance” sufficient to waive the normal requirements for naturalisation considering that the Immigration Act 13 of 2002 requires, in terms of sections 25 to 28, that a person applying for permanent residence in South Africa either be selfsufficient or have a supporting sponsor. The decision to grant naturalisation under the South African Citizenship Act may well be subject to administrative discretion and would therefore be beyond the control of the applicants.58 [57] The respondents argued that the state has an obligation toward its own citizens first, and that preserving welfare grants for citizens only creates an incentive for permanent residents to naturalise. This argument, commonly found in American jurisprudence, is based on the social contract assumption that non-citizens are not entitled to the full benefits available to citizens.59 The argument, however, does not accord with the stated legislative intention in the Immigration Act which provides that: “The holder of a permanent residence permit has all the rights, privileges, duties and obligations of a citizen, save for those rights, privileges, duties and obligations which a law or the Constitution explicitly ascribes to citizenship.”60 Financial considerations 58 See para 65 below. 59 See, for example, Mathews v Diaz 426 US 67, 78 (1976). See also para 66 below. 60 Section 25(1). 35