In celebrating proportionality analysis, commentators have suggested that it can provide a “flexible, but generally more substantive interpretation of positive rights, avoiding both the Scylla of a minimum core approach and the Charybdis of a mere reasonableness test”.120 Yet South African commentary suggests a different operation of proportionality: “proportionality-inflected reasonableness”, as a compromise position. This approach addresses the concerns of weakness within reasonableness review, while avoiding the self-defeating containment doctrines that limit the reach of proportionality analysis in economic and social rights cases, especially those involving positive obligations. A greater attention to the excessive impacts on rights experienced by the most vulnerable allows for a more robust integration of the principle of proportionality into economic and social rights review. Nonetheless, the question remains as to whether a proportionality-inflected reasonableness travels well, beyond our setting of South African constitutional law. Just as one comparative lesson of economic and social rights adjudication is that standardsbased, apparently weak-form adjudicatory postures can (perversely) produce more rightsprotective results than strong form, muscular or managerial adjudication; 121 another comparative lesson is the contingency of this insight. The ability of weak-form review to deliver positive outcomes can depend on a series of contextual factors, including legal or constitutional culture; function or dysfunction on the part of the executive and legislature (and public perceptions of the same); vitality and clout of rights-claiming social 120 121 KLATT & MEISTER, supra note 74, 108. Tushnet, supra note 93. 30