State Accountability for Gender-Based Violence in South Africa: Are Constitutional Duties Being Fulfilled

Introduction 

Gender-based violence (GBV) remains one of the most prevalent and deeply rooted human  rights challenges in South Africa.1 Despite the country’s progressive Constitution and  extensive legislative framework, incidents of violence against women and children continue  to increase at alarming rates. The of gender-based violence in South Africa is staggering. An  article by the The New Humanitarian states that intimate partner femicide rates are almost five times the world average.2It was found by the country’s statutory research agency, the Human Sciences Research Council, that over a three-month period in 2024, 957 women were murdered, 1567 survived attempted murders, and 14366 suffered grievous bodily harm. Over  10000 rapes were also reported to the police, which is only a fraction of the actual number, as  an estimated 95% of cases in the country go unreported.3 South Africa records some of the  highest rates of intimate partner femicide globally, with figures substantially exceeding  international averages.4 Official statistics reflect only a fraction of the lived reality, as  widespread under-reporting obscures the true scale of the crisis.5 The contradiction between  strong legal protections and the persistently increasing rates of violence against women and  children raises serious concerns about state accountability. The prevalence of gender-based  violence not only reflects individual criminal behaviour, but also exposes systemic failures in  prevention, protection, investigation, and prosecution. South Africa’s Constitution was  founded on the values of dignity, equality, and freedom. Thus, South Africa bears the legal and moral obligations to address this crisis effectively. This article examines whether the  South African state is meeting its constitutional duties to protect individuals from gender based violence. 

Legal Framework 

Constitutional Provisions 

The South African Constitution is widely regarded as one of the most transformative  constitutional texts in the world. The Bill of Rights ( Chapter 2 of the Constitution) explicitly  recognises the right to equality, human dignity, life, and freedom and security of the person.6 Section 12(1)(c) of particular importance, as it guarantees the right to be free from all forms  of violence from both public and private sources, along with section 12(1)e, which guarantees  the right to not be treated in a cruel, degrading or inhumane way.7 These provisions place South Africa among a small number of jurisdictions that constitutionally acknowledge the  state’s responsibility to protect individuals from private acts of violence. In addition, section  7(2) obliges the state to respect, protect, promote, and fulfil the rights in the Bill of Rights,  imposing positive duties that extend beyond mere non-interference.8 

Gender-based violence directly undermines and represents a serious and direct infringement  of the rights enshrined in the South African Constitution. Violence strips survivors of dignity,  reinforces patterns of inequality, and threatens life and bodily integrity. Thus, when viewing  gender-based violence from a constitutional perspective, it is not simply a criminal justice  issue but a matter of systemic rights violations.9 The disproportionate impact of violence on  women and children engages substantive equality, which is concerned with achieving real  and meaningful equality in practice, rather than formal equality, which focuses only on  treating everyone the same. Treating people identically is often insufficient to address long standing gendered power imbalances. Consequently, the state’s response to GBV must be  comprehensive, proactive, and effective in both law and practice. 

Legislative Measures 

To give effect to these constitutional obligations, South Africa has enacted several statutes  addressing GBV. The Domestic Violence Act10 was introduced to provide accessible  protection through civil remedies such as protection orders and to impose specific duties on  police officials. The Criminal Law (Sexual Offences and Related Matters) Amendment Act11 modernised the law relating to sexual offences and expanded the scope of protection afforded  to complainants.12 More recent amendments between 2020 and 2022 such as the Criminal and  Related Matters Amendment Act (2021), further strengthened protection-order systems, reporting  obligations, and sentencing provisions.13 Collectively, these statutes reflect a clear legislative  intention to address GBV through a rights-based approach. 

However, legislation alone is insufficient in the absence of effective implementation,  particularly where the Constitution imposes positive duties on the state. Section 7(2) of the  South African Constitution requires the state not only to respect rights, but also to protect,  promote, and fulfil them.14 In the context of domestic violence, this obligation demands more  than the enactment of progressive legislation; it requires active, consistent, and effective  enforcement. Although South Africa’s statutory framework on domestic violence is widely  regarded as robust, its success ultimately depends on proper implementation by the police,  prosecuting authorities, and the courts. 

Judicial Interpretation 

Judicial interpretation has played a critical role in clarifying the scope of the state’s  obligations in relation to GBV. In Carmichele v Minister of Safety and Security, the  Constitutional Court held that the state could be held delictually liable for failing to protect  individuals from foreseeable harm.15 The Court found that the police have positive obligations to protect the fundamental rights and freedoms contained in the Bill of Rights. The police, therefore, had to reasonably protect women from sexual violence, and their failure to do so would result in liability.16 The Court also emphasised South Africa’s duty under international law to prohibit all gender-based discrimination. The Court noted that the police are one of the primary agencies of the state responsible for the protection of the public in general, and women in particular, against the violation of their fundamental rights by perpetrators of violent crime. The  Court emphasised that constitutional rights impose positive duties on the state and that  omissions by police and prosecuting authorities may constitute breaches of these duties.17 This decision marked a significant development in South African law by recognising state  accountability for failures to act in the face of known risks.18 

Subsequent cases reinforced and expanded this principle. In K v Minister of Safety and  Security, the Constitutional Court held the state vicariously liable for acts of sexual violence  committed by police officers who abused their position of authority. The Court reasoned that  the nature of policing creates a special relationship of trust between officers and the public,  and that abuses of this trust engage state responsibility.19 Similarly, in F v Minister of Safety  and Security, the Court confirmed that the state may be liable even where the connection  between the officer’s conduct and official duties is indirect. These judgments collectively  establish that the state bears responsibility not only for legislative failures but also for  institutional and operational shortcomings.20 

Despite this clear jurisprudence, practical enforcement remains inconsistent. Policing failures  are among the most frequently cited barriers to effective protection against GBV. Survivors  often report dismissive attitudes, delayed responses, and inadequate investigations. In some  cases, protection orders are not served or enforced promptly, exposing individuals to further  harm. These failures are particularly concerning given the central role of the police in  fulfilling the state’s constitutional duty to protect. When frontline officials do not act in  accordance with legal requirements, the entire protective framework is weakened. 

Critical Analysis 

Numerous reports by oversight bodies indicate that survivors of domestic violence frequently  encounter significant barriers when attempting to access legal remedies. Police officials may  fail to inform complainants of their rights under the Domestic Violence Act, neglect to  enforce protection orders, or mishandle complaints in ways that minimise the seriousness of  the abuse. Such failures represent more than isolated administrative shortcomings; they  amount to a failure by the state to meet its constitutional obligation to protect individuals  from violence. These deficiencies undermine the protective purpose of the legislation and  contribute to a broader erosion of public confidence in the criminal justice system.21 

The limited ability of the police to assist victims of domestic violence is often characterised  as an institutional failure, commonly attributed to inadequate resources, insufficient training,  or limited operational capacity within the South African Police Service.22 While these  structural challenges are significant and cannot be ignored, empirical research suggests that  they do not fully explain the persistence of domestic violence or its widespread under reporting. A qualitative study conducted in the township of Khayelitsha illustrates the  complexity of police responses to domestic violence and highlights the influence of social  norms and community attitudes on victim behaviour. 23The study found that deeply  entrenched beliefs about gender roles, family privacy, and the acceptability of violence  discourage victims from seeking assistance from the police.24 In this context, law  enforcement is often perceived as ineffective, inappropriate, or inaccessible, even where legal  remedies are formally available. 

These findings demonstrate that the effectiveness of the Domestic Violence Act cannot be  assessed solely through an institutional or procedural lens. Although the Act is widely recognised as a progressive and comprehensive piece of legislation, designed to provide  victims and survivors with meaningful legal protection, its impact is significantly constrained  by broader social and contextual factors. The Act imposes clear obligations on police officials  to assist complainants and ensure that incidents of domestic violence are treated seriously.  25Nevertheless, domestic violence remains an issue and significantly under-reported in South  Africa, suggesting that legal obligations alone are insufficient to secure compliance or to  change entrenched patterns of behaviour. 

Scholars seeking to explain the gap between South Africa’s progressive legislative  framework and the lived realities of victims have identified a range of barriers to the effective  implementation of the Domestic Violence Act. These include institutional challenges such as  inadequate training, limited resources, and poor understanding of statutory duties among  police officials. Additional research highlights the particular difficulties faced by  marginalised women and children in accessing justice, especially in poor and resource-scarce  communities where police-to-community ratios are low, relationships between residents and  law enforcement are characterised by distrust, and economic vulnerability further limits  victims’ ability to seek assistance.26 In such contexts, the state’s constitutional obligation  under section 7(2) is rendered largely theoretical rather than practical. 

Importantly, policing domestic violence is not a neutral or value-free exercise. Law  enforcement interventions in cases of domestic violence require the state to intervene in  private and historically unregulated spheres of family life. For these interventions to be  effective, they must be supported by community norms that recognise domestic violence as a  public concern warranting state intervention. 27Where social attitudes continue to normalise  or excuse domestic abuse, victims are less likely to report violence, and police intervention is  less likely to be viewed as legitimate or appropriate. This reinforces the conclusion that  meaningful state accountability for domestic violence requires not only strong laws and institutional capacity, but also broader societal change that supports victims and affirms the  legitimacy of state protection.28 

The prosecution of GBV-related offences also presents significant challenges. High case  attrition rates, prolonged delays, and limited forensic capacity undermine the effectiveness of  criminal proceedings. Survivors may be required to attend multiple court appearances, relive  traumatic experiences, and navigate a system that is not always sensitive to their needs.29 Without consistent and efficient prosecution, the deterrent effect of the law is diminished, and  perpetrators are less likely to be held accountable. 

Beyond the criminal justice system, structural and socio-economic factors further complicate  the state’s response to GBV. Many survivors lack access to safe accommodation, financial  resources, or long-term support services.30 Shelters and counselling services are often under resourced and concentrated in urban areas, leaving rural communities particularly  vulnerable31. Economic dependence on perpetrators can prevent individuals from leaving  abusive environments, even where legal remedies exist. These realities highlight the  interconnected nature of GBV and socio-economic inequality, reinforcing the need for a  holistic state response.32 

South Africa’s international obligations further reinforce its constitutional duties. The country  is a party to the Convention on the Elimination of All Forms of Discrimination Against  Women (CEDAW) and the Maputo Protocol, both of which require states to exercise due diligence in preventing, investigating, and responding to violence against women. 33Under  international law, a state may be held responsible for private acts of violence where it fails to  take reasonable measures to prevent harm or provide effective remedies. These standards  align closely with South Africa’s constitutional framework and underscore the importance of  implementation rather than mere formal compliance.34 

International monitoring bodies have repeatedly acknowledged South Africa’s strong legal  framework while expressing concern about weak enforcement. Reports emphasise the gap  between law and practice, noting that legislative reforms have not yet translated into  meaningful reductions in violence. This disconnect suggests that the state’s obligations are  not being fully realised in practice. While progress has been made in policy development and  public awareness, structural barriers continue to impede effective protection. 

Recent Developments: GBV is declared a National Disaster 

Recent initiatives, such as the National Strategic Plan on Gender-Based Violence and  Femicide, demonstrate increased political recognition of the crisis. The Plan outlines a  coordinated, multi-sectoral approach involving government departments, civil society, and  the private sector. Its pillars include accountability, justice, survivor support, and prevention.  35However, implementation has been slow, and funding constraints remain a significant  obstacle. Without sustained political will and adequate resources, strategic frameworks risk  becoming symbolic rather than transformative.36 

In November 2025, following sustained public pressure and nationwide protests, the South  African government formally declared gender-based violence and femicide (GBVF) a National Disaster under the Disaster Management Act.37 This declaration marked a significant policy shift, acknowledging GBV not merely as a social or criminal justice  concern, but as a national emergency requiring urgent, coordinated, and adequately resourced  state intervention. The declaration followed widespread demonstrations led by civil society  organisations, most notably Women for Change, which organised a nationwide shutdown on  21 November 2025. Thousands of women, LGBTQI+ individuals, and allies participated in  silent protests across public spaces to commemorate victims of GBVF and to highlight the  pervasive climate of fear under which women live daily.38 The protest was strategically timed  ahead of the 2025 G20 Summit, underscoring the incompatibility between economic progress  and the systemic failure to protect the lives of women and children.39 

The way forward 

Civil society organisations have played a crucial role in holding the state accountable and  providing services where government capacity is lacking. 40Through litigation, advocacy, and  direct support, these organisations have highlighted systemic failures and pushed for reform.  Their involvement underscores the importance of collaborative governance in addressing  GBV. Nevertheless, reliance on civil society cannot absolve the state of its primary  constitutional responsibilities.41 

To fulfil its constitutional and international obligations, South Africa must prioritise effective  implementation and accountability.42 This requires strengthening police oversight  mechanisms, improving training for law enforcement and judicial officers, and ensuring that  survivors receive timely and appropriate support. It also necessitates addressing broader  socio-economic conditions that exacerbate vulnerability to violence. Accountability must be both legal and institutional, with consequences for failures to act in accordance with  constitutional duties.43 

Conclusion 

South Africa possesses a comprehensive and constitutionally grounded legal framework for  addressing gender-based violence. The Constitution, supported by legislation and judicial  interpretation, clearly establishes the state’s obligation to protect individuals from harm and  to respond effectively to violence. However, persistent failures in implementation,  enforcement, and resource allocation reveal a significant gap between legal commitments and  lived realities. 

The challenge confronting South Africa is not the absence of law, but the failure to translate  constitutional promises into practical protection. Until state institutions consistently fulfil  their duties and survivors experience the law as accessible, responsive, and effective, GBV  will remain a profound constitutional failure. Meaningful progress requires sustained political  will, accountable institutions, and a holistic approach that recognises gender-based violence  as both a legal and social crisis. 

Bibliography 

Books: 

• Dlakavu, S. (2022) ‘The road to the National Strategic Plan on gender-based violence  and femicide in South Africa’, Feminist Institutionalism in South Africa.  doi:10.5040/9798881813895. 
• Marsha A, F., Christine, C. and Beate, R. (2012) ‘Violence against women’, The UN  Convention on the Elimination of All Forms of Discrimination Against Women [Preprint]. doi:10.5422/fso/9780199565061.003.0019. 

Cases: 

• Carmichele v Minister of Safety and Security (CCT 48/00) [2001] ZACC 22; 2001 (4)  SA 938 (CC); 2001 (10) BCLR 995 (CC); 2002 (1) SACR 79 (CC) (16 August 2001) • F v Minister of Safety and Security and Another (CCT 30/11) [2011] ZACC 37; 2012  (1) SA 536 (CC); 2012 (3) BCLR 244 (CC); (2012) 33 ILJ 93 (CC); 2013 (2) SACR  20 (CC) (15 December 2011) 
• K v Minister of Safety and Security (CCT52/04) [2005] ZACC 8; 2005 (6) SA 419  (CC); 2005 (9) BCLR 835 (CC) ; [2005] 8 BLLR 749 (CC); (2005) 26 ILJ 1205 (CC)  (13 June 2005) 

Legislation: 

• Criminal and Related Matters Amendment Act 12 of 2021 (South Africa) • Criminal Law (Sexual Offences and Related Matters) Amendment Act 32 of 2007 (South Africa) 
• Domestic Violence Act 116 of 1998 (South Africa) 
• The Constitution of the Republic of South Africa (1996) 

Journals: 

• Mlambo, Victor H & Zubane, Sphephelo & Zubane, P & Mlambo, Daniel. (2019).  Promoting good governance in Africa: The role of the civil society as a watchdog.  Journal of Public Affairs. 20. 10.1002/pa.1989. 
• Mogstad, H., Dryding, D. and Fiorotto, O. (no date) Policing the private: Social  barriers to the effective policing of domestic violence, South African Crime Quarterly.  Available at: https://journals.assaf.org.za/index.php/sacq/article/view/414 (Accessed:  12 December 2025).

Websites: 

• Abrahams N;Chirwa E;Mhlongo S;Dekel B;Ketelo A;Lombard C;Shai N;Ramsoomar  L;Mathews S;Labuschagne G;Matzopoulos R;Prinsloo M;Martin LJ;Jewkes R; (no  date) Two decades of tracking femicide in South Africa: An analysis of four national  surveys from 1999 to 2020/2021, Global public health. Available at:  https://pubmed.ncbi.nlm.nih.gov/41243236/ (Accessed: 10 December 2025).
• Admin (2025) Prosecution challenges in gender-based crime cases., Gendercide.  Available at: https://www.gendercide.org/prosecution-challenges-in-gender-based crime cases/#:~:text=Evidence%20Collection%20and%20Reliability,attorneys%20to%20qu estion%20their%20credibility. (Accessed: 12 December 2025). 
• A duty to protect women (carmichele) – our constitution. Available at:  https://ourconstitution.wethepeoplesa.org/a-duty-to-protect-women/ (Accessed: 11  December 2025). 
• Badenhorst, J. (2024) GBV report reveals scale of underreporting of violent and  Sexual Crimes – Action Society, Action Society. Available at:  https://actionsociety.co.za/gbv-report-reveals-scale-of-underreporting-of-violent-and sexual-crimes-action-society/ (Accessed: 11 December 2025). 
• Gender-based violence UNHCR. Available at: https://www.unhcr.org/what-we do/protect-human-rights/protection/gender-based-violence (Accessed: 11 December  2025). 
• Masumbe, P.S. and Nomnganga, P. (no date) Law and world, Lawandworld. Available  at: https://lawandworld.ge/index.php/law/article/view/791 (Accessed: 12 December  2025). 
• Specter, K. (2024) Social, economic and implementation barriers undermine  effectiveness of three new GBV-laws, warn jantjies, 1000 Woman 1 Voice. Available  at: https://www.1000women.co.za/social-economic-and-implementation-barriers undermine-effectiveness-of-three-new-gbv-laws-warn-jantjies (Accessed: 12  December 2025). 
• To protect human rights for all, we must invest in ending gender-based violence – constitution hill (no date) To protect human rights for all, we must invest in ending  gender-based violence – Constitution Hill. Available at:  https://www.constitutionhill.org.za/blog/to-protect-human-rights-for-all-we-must invest-in-ending-gender-based-violence (Accessed: 11 December 2025).
• Uguru, H. (no date) South Africa finally declares GBV a national disaster, The New  Humanitarian. Available at: https://www.thenewhumanitarian.org/news feature/2025/12/02/south-africa-finally-declares-gbv-national-disaster (Accessed: 10  December 2025)

1To protect human rights for all, we must invest in ending gender-based violence – constitution hill (no date) To protect human rights for  all, we must invest in ending gender-based violence – Constitution Hill. Available at: https://www.constitutionhill.org.za/blog/to protect-human-rights-for-all-we-must-invest-in-ending-gender-based-violence (Accessed: 11 December 2025). 

2Uguru, H. (no date) South Africa finally declares GBV a national disaster, The New Humanitarian. Available at:  https://www.thenewhumanitarian.org/news-feature/2025/12/02/south-africa-finally-declares-gbv-national-disaster (Accessed: 10  December 2025) 

3Uguru, H. (no date) South Africa finally declares GBV a national disaster, The New Humanitarian. Available at:  https://www.thenewhumanitarian.org/news-feature/2025/12/02/south-africa-finally-declares-gbv-national-disaster (Accessed: 10 December  2025). 

4Abrahams N;Chirwa E;Mhlongo S;Dekel B;Ketelo A;Lombard C;Shai N;Ramsoomar L;Mathews S;Labuschagne G;Matzopoulos  R;Prinsloo M;Martin LJ;Jewkes R; (no date) Two decades of tracking femicide in South Africa: An analysis of four national surveys  from 1999 to 2020/2021, Global public health. Available at: https://pubmed.ncbi.nlm.nih.gov/41243236/ (Accessed: 10 December  2025).  

5Badenhorst, J. (2024) GBV report reveals scale of underreporting of violent and Sexual Crimes – Action Society, Action Society. Available  at: https://actionsociety.co.za/gbv-report-reveals-scale-of-underreporting-of-violent-and-sexual-crimes-action-society/ (Accessed: 11  December 2025).

6 The Constitution of the Republic of South Africa (1996) 

7 The Constitution of the Republic of South Africa (1996) 

8 The Constitution of the Republic of South Africa (1996) 

9 Gender-based violence UNHCR. Available at: https://www.unhcr.org/what-we-do/protect-human rights/protection/gender-based-violence (Accessed: 11 December 2025).

10 Domestic Violence Act 116 of 1998 (South Africa) 

11 Criminal Law (Sexual Offences and Related Matters) Amendment Act 32 of 2007 (South Africa) 12 Masumbe, P.S. and Nomnganga, P. (no date) Law and world, Lawandworld. Available at:  https://lawandworld.ge/index.php/law/article/view/791 (Accessed: 12 December 2025). 

13 Criminal and Related Matters Amendment Act 12 of 2021 (South Africa) 

14 Constitution of the Republic of South Africa (1996) 

15Carmichele v Minister of Safety and Security (CCT 48/00) [2001] ZACC 22; 2001 (4) SA 938 (CC); 2001  (10) BCLR 995 (CC); 2002 (1) SACR 79 (CC) (16 August 2001)

16 (No date) A duty to protect women (carmichele) – our constitution. Available at: https://ourconstitution.wethepeoplesa.org/a-duty-to-protect-women/ (Accessed: 11 December 2025).

17 (No date) A duty to protect women (carmichele) – our constitution. Available at: https://ourconstitution.wethepeoplesa.org/a-duty-to-protect-women/ (Accessed: 11 December 2025).

18 (No date) A duty to protect women (carmichele) – our constitution. Available at: https://ourconstitution.wethepeoplesa.org/a-duty-to-protect-women/ (Accessed: 11 December 2025).

19 K v Minister of Safety and Security (CCT52/04) [2005] ZACC 8; 2005 (6) SA 419 (CC); 2005 (9) BCLR 835  (CC) ; [2005] 8 BLLR 749 (CC); (2005) 26 ILJ 1205 (CC) (13 June 2005) 

20 F v Minister of Safety and Security and Another (CCT 30/11) [2011] ZACC 37; 2012 (1) SA 536 (CC); 2012  (3) BCLR 244 (CC); (2012) 33 ILJ 93 (CC); 2013 (2) SACR 20 (CC) (15 December 2011)

21 Mogstad, H., Dryding, D. and Fiorotto, O. (no date) Policing the private: Social barriers to the effective  policing of domestic violence, South African Crime Quarterly. Available at: https://journals.assaf.org.za/index.php/sacq/article/view/414 (Accessed: 12 December 2025). 

22 Mogstad, H., Dryding, D. and Fiorotto, O. (no date) Policing the private: Social barriers to the effective  policing of domestic violence, South African Crime Quarterly. Available at: https://journals.assaf.org.za/index.php/sacq/article/view/414 (Accessed: 12 December 2025).

23 Mogstad, H., Dryding, D. and Fiorotto, O. (no date) Policing the private: Social barriers to the effective  policing of domestic violence, South African Crime Quarterly. Available at: https://journals.assaf.org.za/index.php/sacq/article/view/414 (Accessed: 12 December 2025).

24 Mogstad, H., Dryding, D. and Fiorotto, O. (no date) Policing the private: Social barriers to the effective  policing of domestic violence, South African Crime Quarterly. Available at: https://journals.assaf.org.za/index.php/sacq/article/view/414 (Accessed: 12 December 2025).

25 Mogstad, H., Dryding, D. and Fiorotto, O. (no date) Policing the private: Social barriers to the effective  policing of domestic violence, South African Crime Quarterly. Available at: https://journals.assaf.org.za/index.php/sacq/article/view/414 (Accessed: 12 December 2025).

26 Specter, K. (2024) Social, economic and implementation barriers undermine effectiveness of three new GBV laws, warn jantjies, 1000 Woman 1 Voice. Available at: https://www.1000women.co.za/social-economic and-implementation-barriers-undermine-effectiveness-of-three-new-gbv-laws-warn-jantjies (Accessed:  12 December 2025). 

27 Mogstad, H., Dryding, D. and Fiorotto, O. (no date) Policing the private: Social barriers to the effective  policing of domestic violence, South African Crime Quarterly. Available at: https://journals.assaf.org.za/index.php/sacq/article/view/414 (Accessed: 12 December 2025).

28 Mogstad, H., Dryding, D. and Fiorotto, O. (no date) Policing the private: Social barriers to the effective  policing of domestic violence, South African Crime Quarterly. Available at: https://journals.assaf.org.za/index.php/sacq/article/view/414 (Accessed: 12 December 2025).

29 Admin (2025) Prosecution challenges in gender-based crime cases., Gendercide. Available at:  https://www.gendercide.org/prosecution-challenges-in-gender-based-crime cases/#:~:text=Evidence%20Collection%20and%20Reliability,attorneys%20to%20question%20their%2 0credibility. (Accessed: 12 December 2025). 

30 Specter, K. (2024) Social, economic and implementation barriers undermine effectiveness of three new GBV laws, warn jantjies, 1000 Woman 1 Voice. Available at: https://www.1000women.co.za/social-economic-and implementation-barriers-undermine-effectiveness-of-three-new-gbv-laws-warn-jantjies (Accessed: 12 December  2025). 

31 Specter, K. (2024) Social, economic and implementation barriers undermine effectiveness of three new GBV laws, warn jantjies, 1000 Woman 1 Voice. Available at: https://www.1000women.co.za/social-economic-and implementation-barriers-undermine-effectiveness-of-three-new-gbv-laws-warn-jantjies (Accessed: 12 December  2025). 

32 Specter, K. (2024) Social, economic and implementation barriers undermine effectiveness of three new GBV laws, warn jantjies, 1000 Woman 1 Voice. Available at: https://www.1000women.co.za/social-economic-and implementation-barriers-undermine-effectiveness-of-three-new-gbv-laws-warn-jantjies (Accessed: 12 December  2025).

33 Marsha A, F., Christine, C. and Beate, R. (2012) ‘Violence against women’, The UN Convention on the  Elimination of All Forms of Discrimination Against Women [Preprint].  

doi:10.5422/fso/9780199565061.003.0019.  

34 Marsha A, F., Christine, C. and Beate, R. (2012) ‘Violence against women’, The UN Convention on the  Elimination of All Forms of Discrimination Against Women [Preprint].  

doi:10.5422/fso/9780199565061.003.0019. 

35 Dlakavu, S. (2022) ‘The road to the National Strategic Plan on gender-based violence and femicide in South  Africa’, Feminist Institutionalism in South Africa. doi:10.5040/9798881813895. 

36 Dlakavu, S. (2022) ‘The road to the National Strategic Plan on gender-based violence and femicide in South  Africa’, Feminist Institutionalism in South Africa. doi:10.5040/9798881813895. 

37 Uguru, H. (no date) South Africa finally declares GBV a national disaster, The New Humanitarian. Available at:  https://www.thenewhumanitarian.org/news-feature/2025/12/02/south-africa-finally-declares-gbv-national-disaster (Accessed: 10 December  2025)

38 Uguru, H. (no date) South Africa finally declares GBV a national disaster, The New Humanitarian. Available at:  https://www.thenewhumanitarian.org/news-feature/2025/12/02/south-africa-finally-declares-gbv-national-disaster (Accessed: 10 December  2025) 

39 Uguru, H. (no date) South Africa finally declares GBV a national disaster, The New Humanitarian. Available at:  https://www.thenewhumanitarian.org/news-feature/2025/12/02/south-africa-finally-declares-gbv-national-disaster (Accessed: 10 December  2025) 

40 Mlambo, Victor H & Zubane, Sphephelo & Zubane, P & Mlambo, Daniel. (2019). Promoting good  governance in Africa: The role of the civil society as a watchdog. Journal of Public Affairs. 20.  10.1002/pa.1989. 

41 Mlambo, Victor H & Zubane, Sphephelo & Zubane, P & Mlambo, Daniel. (2019). Promoting good  governance in Africa: The role of the civil society as a watchdog. Journal of Public Affairs. 20.  10.1002/pa.1989. 

42 Mlambo, Victor H & Zubane, Sphephelo & Zubane, P & Mlambo, Daniel. (2019). Promoting good  governance in Africa: The role of the civil society as a watchdog. Journal of Public Affairs. 20.  10.1002/pa.1989.

43 Mlambo, Victor H & Zubane, Sphephelo & Zubane, P & Mlambo, Daniel. (2019). Promoting good  governance in Africa: The role of the civil society as a watchdog. Journal of Public Affairs. 20.  10.1002/pa.1989.