Share
Tuesday, May 31, 2022
Share

Nature of the Case

In 2016, the Minister of Basic Education in South Africa issued a circular announcing that children unable to produce birth certificates would be barred from attending public school. The circular sought to exclude thousands of children from school and had indeed begun to have the effect that some children were removed from school or were denied access on application to enter.  As a result, 37 children, who were only some of the applicants involved in this matter, brought an application against the Minister of Basic Education. They stated that their constitutional right to a basic education was violated by the circular, as well as the national Admission Policy for Ordinary Public Schools and the Immigration Act 13 of 2002. Accordingly, they sought declaratory relief pronouncing the Admission Policy and Immigration Act invalid. Ultimately, the court held that the highlighted provisions in the Admission Policy and Immigration Act 13 of 2002 were unconstitutional and ordered the respondents to accept alternative proof of identity when learners cannot provide birth certificates or proof of study permits. The court reasoned that denying undocumented children access to education was inconsistent with the Constitution, which provides rights to equality, dignity, and basic education, and further declares children’s best interests to be of paramount importance. Additionally, the court determined that the Immigration Act applies only to adults seeking higher education, and therefore does not interfere with children’s right to basic education.

Enforcement of the Decision and Outcomes

The court declared the relevant sections of the Admission Policy unconstitutional, deemed it invalid, and declared that the Immigration Act did not prevent undocumented children from being admitted to public school or receiving basic education. In addition, the court ordered the defendants to accept alternative proof of identification for students unable to present a birth certificate, such as a sworn statement deposed by a parent, caregiver, or guardian that identifies the student.

Significance of the Case

The judgment affirms the right of all children, regardless of their ability to produce a birth certificate, to receive basic education in South Africa. Numerous socio-economic and legislative barriers prevent many parents and guardians from obtaining official documentation for their children. The court order allowing parents and guardians to provide alternative proof of identification alleviates the challenges associated with securing official documentation. Furthermore, the decision emphasizes that education should not be viewed as a privilege based on documentation status, but rather as a right.

For their contributions, special thanks to ESCR-Net members: the Program on Human Rights and the Global Economy (PHRGE) at Northeastern University.

Groups Involved in the Case