Black Sash Submissions

As documented in the South African Constitution, any individual or organisation have the right to involvement in law-making and the processes of Parliament. A submission is the presentation of opinions on a matter or piece of legislation which is under consideration by a Parliamentary committee. Through a submission, members of the public can propose changes or suggest possible actions to ensure that the laws being implemented serve their purpose.

This is a collection of the submissions put forward by The Black Sash.


12 February 2018

The Black Sash generally supports the amendment to make provision for debt intervention to accommodate those who are grant recipients who are considered as a vulnerable group for unsecured debt- taking into account their vulnerability exploiting their struggle to make ends meet while having secure income. The adverse impact of loans on recipients, especially where the loans are provided fraudulently, illegally and unlawfully by reckless lenders must be considered to protect recipients and impose harsh penalties on credit providers who are reckless lenders. The application process for debt intervention must be simplified to be user friendly with prescribed forms.

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Black Sash submits that the protection of social grants from unlawful deductions is a seminal element of the right to social security/assistance as set out in the Constitution and International Law. 

We therefore take the view that tightening the provisions pertaining to deductions from social grants is necessary for the protection of social grants. Any failure to do so, by the state, constitutes a failure to protect the right and therefore an independent human rights violation. Black Sash is also of the view that Draft Amendment should be further tightened. 

In summation, Black Sash submits that the DSD should amend the Draft Amendment for better alignment to South Africa’s Constitution and jurisprudential law which requires the state respect, protect, promote and fulfil the right to social security and to take account the demands of International law on a state. 

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