Authored By: Kwanele Msibi
University of the Western Cape
INTRODUCTION
On 25 May 2025, Olerato Mongale, a 30-year-old Wits student, was murdered after goingona date with a man known only as “John.” Her body was found dumped in LombardyWest, Johannesburg, despite her efforts to stay safe by sharing her location with friends.1 Her deathis one of thousands in South Africa’s ongoing femicide crisis, where women are killednot bystrangers, but by those closest to them. Olerato’s murder is not an isolated tragedy; it is part of a devastating pattern of gender-based violence and femicide (GBVF) that continuestoplague South Africa.2
According to the UN, the country’s GBVF rate is five times the global average, availabledatafrom France, South Africa, and Colombia reveals a pattern: a significant portion of womenkilled by their intimate partners, ranging from 22% to 37%, had previously reportedexperiencing physical, sexual, or psychological violence from the same person.3 Despiteprogressive laws like the Domestic Violence Act 116 of 1998, the Criminal Law(Sexual Offences and Related Matters) Amendment Act 32 of 2007, and the National StrategicPlanon GBVF, gaps in implementation, underreporting, and systemic failures continue toleavesurvivors vulnerable and perpetrators unaccountable.
The judiciary has increasingly recognized GBVF as a constitutional issue, with landmarkcases such as S v Baloyi affirming the state’s duty to protect victims. Yet, the persistenceoffemicide and gender-based violence, often at the hands of intimate partners, demands morethan reactive justice. It calls for a reckoning, a legal, cultural, and institutional transformationthat prioritizes survivor dignity, prevention, and accountability. This article explores thelegal landscape surrounding gender-based violence and femicide in South Africa, examiningkeycases, legislative frameworks, and the urgent need for reform. It seeks to illuminate thepathtoward justice for shattered lives and challenge the silence that allows violence to thrive.
LEGAL FRAMEWORK
Gender-based violence and femicide in South Africa are governed by key pieces of statutesdesigned to protect victims and hold perpetrators accountable. The Domestic ViolenceAct 116 of 1998 aims to offer victims the highest level of protection the lawcan provide, requiring government bodies to uphold its provisions and affirming the State’s commitment to ending domestic abuse.4 Building on this, the Criminal Law (Sexual Offences andRelatedMatters) Amendment Act 32 of 2007 targets various forms of sexual violence, includingrape, and establishes clear processes for prosecution and sentencing, emphasizing that sexual crimes are not isolated from the broader issue of gender-based violence.5 Most recently, theNational Council on Gender-Based Violence and Femicide Act 9 of 2024 recognizes that GBV and femicide are deeply rooted social evils, disproportionately affecting society’s most vulnerable people.6 It acknowledges the many ways violence can manifest and asserts that only a coordinated effort uniting government institutions and communities can effectivelyconfront and eliminate this crisis.7 Together, these statutes reflect a legal systemthat seesGBV not just as a crime, but as a moral and constitutional affront requiring urgent, sustained, and collective action.
In South Africa, Chapter 2 of the Constitution, the Bill of Rights, stands as the foundationofour legal system, providing every person with fundamental protections that must never beoverlooked, especially in cases of gender-based violence and femicide.8 Section 9(1) affirmsthat all individuals are equal before the law and deserve equal protection and benefits, regardless of gender, background, or circumstances.9 This principle of equalityis not theoretical; it requires the justice system to respond decisively when women and girls areharmed or denied safety. This is connected to Section 10, which guarantees the right todignity, emphasizing that every person’s worth must be respected and protected.10 Whenwomen are abused, degraded, or silenced, it is not only a societal failure but alsoaconstitutional breach. Additionally, Section 11 enshrines the right to life, clearly statingthat no one may be unjustly deprived of their life.11 Femicide, therefore, is not just a crime; it isadirect violation of the country’s highest law. Section 12 extends this protection by affirmingthe right to freedom and security, including the right to live free from violence, torture, and abuse.12 In a nation where gender-based violence remains a national crisis, theseconstitutional provisions are not mere ideals; they are binding commitments. Upholdingthemis not optional; it is a legal and moral duty that must inform every policy, prosecution, andact of justice.
JUDICIAL INTERPRETATION
In S v Manyathi (CC70/2024) [2025] ZAECGHC 5, for over three years, the Deceasedlivedin a domestic relationship with the Accused, supporting not only him but also her extendedfamily.13 As the sole breadwinner employed at Rhodes University, she also provided financial assistance to her brother, Mr. Mondze, in whose home she and the Accused resided.14 Therelationship ended tragically. The Accused was convicted of attempted murder andmurder, both crimes falling under section 51(1) of the Criminal Law Amendment Act, 1997, duetotheir connection to domestic violence.15 On 3 December 2023, while intoxicated, the coupleargued after the Deceased received calls, one from an unknown man.16 Fueled by jealousyand suspicion, the Accused poured brandy over her.17 She retaliated, and the confrontationescalated into violence. He shattered a glass and stabbed her repeatedly in the head, neck, andhands.18 He admitted he foresaw the possibility of her death and accepted it, despite his angerand intoxication. Months later, after another alcohol-fueled event, the violence escalatedfatally.19 The Accused, again consumed by jealousy, physically assaulted the Deceasedwithbrutal force, strangling her with his hands and possibly a belt, kicking and punching her, andslamming her into furniture.20 Her injuries were catastrophic, such as brain trauma, facial swelling, and deep lacerations.21 She died in agony, unable to breathe. The Accused, realizingshe was dead, covered her body and left.
The court handed down a sentence of 23 years for attempted murder and 28 years for murder, with both sentences to run concurrently.22 This means the Accused will serve an effectiveterm of 28 years in prison. In addition, the Accused is legally barred fromowningor possessing a firearm.23 Notably, the court directed the Registrar to forward the judgment tothe Minister of Health, highlighting a critical concern that the current labeling onalcohol containers fails to adequately warn the public about the connection between alcohol abuseand gender-based violence.24
In S v Baloyi and Others (CCT29/99) [1999] ZACC 19; 2000 (1) BCLR 86; 2000 (2) SA425(CC) (3 December 1999), the complainant laid an assault charge against the appellant andobtained an interdict under the Prevention of Family Violence Act 133 of 1993.25 Thisinterdict ordered the appellant not to assault or threaten the complainant and their child, norto prevent them from entering or leaving their joint home. A warrant for the appellant’s arrest was issued simultaneously but suspended, pending compliance with the interdict.26 Theappellant allegedly assaulted the complainant again and threatened to kill her.27 Thecomplainant reported this, made an affidavit, and the police arrested the appellant. Theappellant was brought before a magistrate for an enquiry into the alleged breachof theinterdict.28 Section 3(5) of the Act specified that the procedure for such an enquiryshouldfollow Section 170 of the Criminal Procedure Act, 1977. This section addresses an accused’sfailure to appear or remain in attendance at criminal proceedings.29 It states that the court mayconvict the accused of the offence unless the accused satisfies the court that his failurewasnot due to fault on his part.
Magistrate, applying an onus being on a balance of probabilities, found the appellant’sversion improbable and untrue. The appellant was convicted of violating the interdict andsentenced to twelve months’ imprisonment, with six months suspended.30 The appellant appealed to the Transvaal High Court, arguing that Section 3(5) of the Act, by incorporatingSection 170 of the CPA, imposed a reverse onus on him, requiring him to prove his innocence. He contended this infringed his constitutional right to be presumed innocent under Section 35(3)(h) of the Constitution.31 The High Court upheld the appellant’s contention, declaredSection 3(5) of the Act invalid, and referred its decision to the Constitutional Court forconfirmation, as required by Section 167(5) and Section 172(2)(a) of the Constitution.32 TheConstitutional Court addressed three main arguments raised by intervening parties, theMinister of Justice and the Commission for Gender Equality, challenging the HighCourt’sdecision. The Court concluded that an alleged violator of an interdict, who faces convictionfor an offence and potential imprisonment, is indeed an accused person as contemplatedbySection 35(3)(h) of the Constitution and is therefore entitled to the benefit of the presumptionof innocence.33 The Court highlighted that the objective of Section 6 of the Act is to punishacompleted violation, not merely to compel compliance. The Court critically examinedSection 3(5) of the Act, read with Section 170 of the CPA. It found the language obscurebut ultimately adopted the first interpretation, reading Section 3(5) as only importingtheprocedural provisions of Section 170 of the CPA for the enquiry.34 The question of whobearsthe burden of proof, a reverse onus, is a matter of substantive law, not procedural law. Therefore, Section 3(5) of the Act, properly construed, does not impose a reverse onus ontheaccused.35 This interpretation was deemed to best promote the spirit, purpose, and objectsofthe Bill of Rights and appropriately balance the state’s duty to address domestic violencewiththe accused’s right to a fair trial, leaving the presumption of innocence undisturbed. SincetheCourt concluded that Section 3(5) did not impose a reverse onus, it found it unnecessarytoconsider whether such a limitation on the presumption of innocence could have beenconstitutionally justified under Section 36 of the Constitution.36
CRITICALANALYSIS
South Africa’s legal system is slowly changing, but not fast enough to meet the urgencyofthe gender-based violence and femicide crisis. Survivors are still left exposed due toseriousgaps in the law and its enforcement. One major issue is that perpetrators often receivebail, and crimes like femicide and domestic violence are not treated with the seriousness they deserve. Sentences handed down often fail to reflect the brutal impact these crimes haveonvictims. Victims also face long delays; cases are postponed, investigations drag on, andjustice is denied for months or even years. Many GBV cases reported to police never reachtrial. Some victims withdraw their complaints, often out of fear or frustration. Police stationslack proper facilities like victim-friendly rooms, and there’s a shortage of trained officers whoknow how to handle rape kits.Worse still, some police officers discourage victims frompursuing justice, telling them to reconcile with their abusers or claiming they can’t intervene. Many survivors are too afraid to report the abuse, and without proper support, theyremainsilent. These failures show that without urgent reform, the law continues to fail thosewhoneed it most.
Comparative models from other jurisdictions offer powerful insights, but South Africa’s pathto justice demands more than borrowed frameworks; it requires bold legislative reform, institutional accountability, and a cultural shift that treats gender-based violence and femicide(GBVF) as a national emergency. Canada’s Criminal Code addresses a wide range of violent offenses, including sexual assault and domestic abuse.37 The country has implementedaNational Action Plan to End Gender-Based Violence, which focuses on prevention, survivorsupport, and justice system reform.38 Importantly, Canada acknowledges the disproportionateimpact of GBVF on Indigenous women and has developed tailored programs to meet theirspecific needs, an example of intersectional justice in practice. Spain, too, has built a robust legal and institutional response.39 Its Organic Law on Integral Protection Measures Against Gender Violence offers a comprehensive framework that includes criminal sanctions, protection orders, and specialized support services.40 Spain has also established dedicatedGBV courts and tribunals, ensuring that cases are handled by trained professionals withurgency and sensitivity.41 Public awareness campaigns further reinforce the societal rejection of violence against women.42 These models show that meaningful change is possible but onlywhen law, policy, and culture work together.
RECENT DEVELOPMENTS
In response to this crisis, several key legislative amendments have been introducedtostrengthen the justice system’s approach to these crimes. The Criminal and RelatedMattersAmendment Act, 2021 (Act 12 of 2021), now makes it harder for individuals accusedofgender-based violence to be granted bail.43 Courts are required to consider the nature of theoffense and the risk posed to victims before releasing suspects, signalling a shift towardprioritizing survivor safety. Changes to the Criminal Procedure Act and the Criminal LawAmendment Act of 1997 have increased the minimum sentences for violent crimes, especially those involving gender-based violence.44 These amendments reflect a growingintolerance for leniency in cases that leave lasting scars on victims and communities. Thenewly enacted Domestic Violence Amendment Act 14 of 2021 introduces a groundbreakingfeature, such that victims of domestic violence can now apply for protection orders online.45This innovation removes barriers to access and empowers survivors to seek help swiftlyanddiscreetly. The same Act also places legal obligations on officials in the DepartmentsofHealth and Social Development to provide essential services to victims.46 This includescounselling, shelter, and medical assistance, ensuring that survivors are not left to navigatetheir trauma alone.47
In a country haunted by the relentless tide of gender-based violence and femicide, SouthAfrica has taken a decisive legislative step toward systemic change. The introductionof theNational Council on Gender-Based Violence and Femicide Act 9 of 2024 marks a pivotal moment in the nation’s legal reckoning. This Act establishes a formal body, the National Council, tasked with leading the strategic fight against gender-based violence and femicide.48Its mandate is clear to unify government departments, civil society, and communitystakeholders under a coordinated, multi-sectoral framework that confronts the crisis head-on. The Council is not merely symbolic.49 It is designed to drive policy reform, monitorimplementation, and ensure accountability across all sectors. By centralizing leadershipandoversight, the Act aims to dismantle fragmented responses and replace themwith a cohesivenational strategy rooted in prevention, protection, and justice.50 Importantly, the legislationemphasizes survivor-centred approaches, ensuring that the lived experiences of victimsinform the Council’s priorities.51 This shift signals a deeper commitment to restoringdignityand delivering justice not just through punishment, but through healing and structural transformation.
In response to South Africa’s escalating gender-based violence and femicide crisis, termedthe“second pandemic” by President Ramaphosa, the government has enacted sweeping reforms, including the National Strategic Plan on GBVF (2020–2030) and the 2024 National Council on GBVF Act, establishing a statutory body for cross-sector coordination.52 Despite thesemeasures, systemic failures persist, and survivors face coercion, as seen in a Middelburgcasewhere a woman, shot by her husband, was pressured into supporting his bail.53 Minister ofPolice Senzo Mchunu condemned such manipulation, urging victims to pursue justice.54 Anational study revealed that 36% of women have endured physical or sexual violence, withentrenched patriarchal norms, and 70% of men believe wives must obey husbands, fuelingimpunity.55 Media and watchdogs continue to spotlight the urgent need for legal accountability and cultural transformation.
SUGGESTIONS
Capital punishment might be the only way to eliminate crimes that cause deathfully. Although South Africa’s Constitution guarantees the right to life and human dignity, acarefully limited reintroduction of the death penalty could apply only to thosewhounlawfully take another person’s life. Under this approach, both victims and perpetratorswould be respected equally for their right to life: anyone convicted of murder wouldfacethesame ultimate punishment, unless genuine self-defense is proven. Bringing back this penaltywould strengthen the rule of law by discouraging potential offenders and reaffirmingtheprinciple of legal equality. By aligning the severity of the punishment with the seriousnessofthe crime, the State would show its dedication to protecting life and deliveringjustice, especially in efforts to combat gender-based violence and other deadly crimes.
Society and the expert doctors must encourage individuals enduring psychological traumatoseek professional support from qualified psychologists or therapists. Recognizing that manycannot afford private care, the State bears an obligation to identify those in financial needandsubsidize or waive treatment fees, ensuring equitable access to mental health services. Moreover, entrenched gender stereotypes, namely, the assumption that men must dominateand women remain submissive, ought to be dismantled. Such beliefs erode self-worth, fuel resentment, and exacerbate domestic tensions. Reforming these norms will foster healthierinterpersonal relationships and mitigate the broader social harm. Additional strategies that canbe established are the community mental health centres staffed by multidisciplinary teamstodeliver affordable, culturally sensitive care. Implementation of government-subsidizedtreatment vouchers or sliding-scale fee structures to remove cost barriers. Integrationofgender-equality and emotional-well-being curricula into schools, workplaces, andpublicforums. Launching nationwide awareness campaigns that destigmatize therapy and promotepositive, non-hierarchical partnerships. Enactment and enforcement of more legislationprotecting victims of domestic unrest and ensuring legal recourse for survivors, and workinghand in hand with other countries.
CONCLUSION
Gender-based violence and femicide (GBVF) in South Africa have reached crisis levels. Thegovernment has called it a national emergency, launching the National Strategic PlanonGBVF and passing the 2024 National Council on GBVF Act to improve coordinationandsurvivor support. Yet, many victims still face pressure to withdraw charges, as seen inacasewhere a woman was shot by her husband and later supported his bail under duress. Deep-
rooted gender norms and weak enforcement continue to fuel abuse, with studies showingthat over a third of women have experienced violence. This is not just a social issue; it’s alegal and moral failure. If GBVF is our second pandemic, then justice must be our cure. Will SouthAfrica finally protect its most vulnerable, or keep letting broken systems fail them?
BIBLIOGRAPHY
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