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IS SECTION 100 INTERVENTION NORMATIVE OR PREROGATIVE?

The announcement by the South African National Cabinet that it will be invoking Section 100 (1) (b) of the Constitution of South Africa to address the ‘apparent crisis’ in the North West Province, particularly in the health sector, has brought the use of the section onto the sharp edge of the analysis sword; governance speaking. This is further complicated by the fact that Cabinet indicates the main objective of the intervention as; ‘to restore trust and confidence between labour and government’; ‘assist the province to upgrade its systems and capabilities to a normality’; ‘ensure compliance with the legislative and regulatory framework of government’; ‘stabilise the labour environment’; ‘restore sustainable service delivery’; ‘ensure security of staff’ and ‘improve financial management’.

The objectives of the intervention are indicative of what constitutes the ‘apparent crisis’ from the vintage point of ‘analyses’ that served as the primal input into Cabinet processes and thus generated the decision. It is always expected that the National Executive of a country like South Africa will take a decision of this magnitude on the basis of a thorough process that valorises the audi alteram partem principle. The Constitution entrenches section 100 as one of the instruments to facilitate ‘national supervision of intervention in provincial administration’ in the circumstance ‘a province cannot or does not fulfil an executive obligation in terms of the Constitution or legislation’. It is thus premised on the performance of the provincial administration and not the ‘politics’ instructing to the system.

A closer look at the constitutional provision reveals a necessity for process before the invoking of section 100. The invoking of section 100 is in fact an intergovernmental relations intervention mechanism provided for in the Constitution. It flows from co-operative governance principles which are the basis of South Africa’s intergovernmental relations philosophy and governance, and is based on a reciprocal obligation of spheres of government to trust, support and assist one another in co-coordinating service delivery.  This includes a legal, political and moral obligation to inform and consult one another as well as co-operating with and co-ordinating efforts on matters of common concern and joint projects, thus patterning intergovernmental collaboration and co-operation to ensure the success of the national development project.  

 ‘Executive obligations’ mentioned in the constitution, unless otherwise explained in another legislation, are understood to be specified in section 125 of the constitution dealing with the Executive Authority of provinces. Pyramiding this authority is it being vested in the Premier, and exercising it together with members of the Executive Council, and subject to provisions of section 100. The discretion of section 100 implementation looms therefore large in the absence of further circumscription by section 100 (3) of the constitution. It can thus be concluded that executive obligations are those in legislations promulgated in terms of the constitution, and anything outside that is either exogenous to them or discretionary to the extent the nature of politics dictate or allow.

The provisions dealing with conditions that necessitate assuming responsibility for the ‘obligation’ where ‘failure is observed, reported and/or perceived’ are specified as being ‘invokable’ to the extent necessary to inter alia  maintain essential national standards for the rendering of a service; maintain economic unity and national security; and to prevent a province from taking action that is prejudicial to the interests of the country, or another province. In respect of the North West Province, this exigency existed and it was acute in the department of health as a result of then and ongoing strike by NEHAWU and the absence of leadership to deal with the strike itself, whence Cabinet had the objective of ‘restoring trust and confidence between labour and government’.

The exigency that propelled the need to invoke section 100 in the North West Department of health was however not as a result of the fact that the Provincial Department of Health ‘cannot or does not fulfil an executive obligation in terms of the Constitution or legislation’. Evidence is that the NWDoH faced industrial action that rendered it dysfunctional and could therefore not fulfil its service delivery obligations in Ngaka Modiri Molema District based Mafikeng jurisdiction, where industrial action was acute and integrated with grievances emanating from the body politic internal to the ruling party, the ANC. The intensity of the strike at NWDoH rendered the provincial department’s centre ungovernable and obligations related to the day to day management of the department could not be fulfilled; even at remote sites because the ‘strike command centre’ took full control of the NWDoH head office and had the capacity to effect changes and reversals to management decisions including interfering with the suppliers payment systems of BAS.

Notwithstanding, section 100 actually directs the national executive to amongst others ‘issue a directive to the provincial executive it is intervening at, describing ‘the extent of the failure’ to fulfil its obligations and stating any steps required to meet its obligations. The description, and as the constitution provides, assumes the existence of a process to investigate before actual intervention occurs, of course without vitiating the possibility of operating with a context of an emergency; manufactured, real or perceived. The constitution does not provide for a process to deal with exigencies emanating for circumstances that are ‘political’ and/or exogenous to those that relate to ‘failure to fulfil an executive obligation’; save to implore of the national executive through Parliament, to establish such a process through legislation envisaged in section 100 (3). In the absence of such a provision, discretion becomes the final arbiter. Except for the court ruling induced Intergovernmental Relations Framework Act, Act 13 of 2005 ,which in itself is silent on a section 100 process, there is no legislation that regulates supervision and intervention in sub-national governments in the event of conditions similar to those that obtained in the North West when Cabinet intervened; this leaves the intervention process in a prerogative realm of state governance and management.

Without vitiating the absence of legislation envisaged in section 100 (3), the Corporative governance principles provide a conceptual sieve within which executive overreach in the invoking of this section can be regulated or circumscribed. The focus of section 100 on failure to fulfil an executive obligation posits the invoking of the section within the normative realm that most constitutions in democracies seek to aspire to. The wisdom of constitution drafters, which included the person of President Cyril Ramaphosa, in establishing a normative framework as reflected in chapter 3 of the constitution whilst making provision for the section 100 interventions, would have been focused or targeted the repugnancy threat that is inherent in democracies that have sub-national jurisdictions with ‘executive authority powers’. The application of section 100 can therefore not be exercised within the prerogative realm often reserved for the ‘political’ in the administration of the state.

It is this article’s submission that the absence of an articulative intergovernmental relations policy framework envisaged in 100 (3) as well as sections 41(2), 139(8) and 155(6)(a) of the Constitution, makes interventions in sub-national political and administrative jurisdictions a prerogative endeavour that has questionable normative justifications. The above provisions, read with Chapter 13 of the Constitution providing for general financial matters, procure for the enactment of legislation or a regulatory framework; to establish structures and institutions to promote and facilitate intergovernmental relations; to provide for appropriate mechanisms and procedures to facilitate the settlement of intergovernmental disputes; to regulate the process that national government should follow in determining the extent to which a provincial government could not fulfil or is not fulfilling its obligation in terms of the constitution or national legislation; to regulate and provide for mechanisms and processes, either than those provided for in the constitution, that facilitate a normative and/or standardised for provincial intervention in local government; provide for the monitoring and support of local government in the province, a condition precedent activity between national and provincial. These provisions, and left unattended, can only increase the discretionary reach and scope of executive power to levels where the vagueness of policy may spill over into a tacit authorisation of administrative bodies to intervene in the socio-economic as well as political life of the nation; a critical indicator of the encroachment of dictatorship.

 In invoking section 100 in the North West, the National Executive made reference to an ‘apparent crisis’ that was either existing or developing. The ‘apparent’  nature of the crisis would have only been the to the purview of the arguments and background provided as input to the Cabinet meeting of 24th April 2018. Save for the media-inspired information on the ‘apparent crisis’ and matters posited as the objective of the intervention, there seems to have not been an answering information and or affidavit from the provincial government, that preceded the intervention. A high level read of accounts of the Auditor-General, one of the Constitutionally created key institutions charged with reporting indicators of performance of various administrative units of the state, indicates that the office of the Premier in particular, had been on an upward trajectory performance and compliance wise. In respect of other departments in the North West, reports from the AG office indicate that there were noticeable improvements since the 5th Administration took over and consequence management processes were in place when the ‘intervention’ occurred. In fact there is a less reported case on consequence management traceable to the ungovernability ructions, where a member of the SMS was disciplined and ultimately dismissed, with a number of colluders facing various charges related thereto.

The absence therefore, of section 100(3) legislation to regulate the process established by section 100 creates a lacuna in the intervention procedure. In its current format the intervention process makes the entire section 100 vulnerable to a ‘settling of scores’ circumstance where national government may descend on a provincial government for non-administrative reasons or in the parlance of the Constitution, for reasons of not related to non-fulfilment of an ‘executive’ obligation. In his seminal work on the legacies of law, Meierhrnrich submits that laws should carry structures and systems of society through time; laws should insert the common interest of society into the behaviour of society-members; laws should establish the futures for society in accordance to what norms that society[1]. In a society that apexes its Constitution as the supreme law of the land and espouses the rule of law as the fundamental guide to its jurisprudence, any abolition of the inviolability of the law becomes a recipe for the establishment of a prerogative state and thus puts into question the very significance of the law.

The rule of law positions laws of the state as legal innovations that enable democracies to coordinate activities within society efficiently, they are a form of power. In fact, established orthodoxies in society are best abstracted in the legal order established, whence the ‘establishment’ in society is anchored on how it manipulates its ways through what the law provides. Politics being the outcome of interest management, the negotiation of interests, and the aggregation of information instructing the diversity of such interests within a context that creates in a society a habit of legality, requires from those charged with the dispensing of State Power a normative sensitivity when invoking sub-national intervention provisions of the constitution. The manner in which such invoking occurs creates in society continuity patterns that may settle as a socialisation of the ‘political community’ and thus mutating into a ‘school of thought’ deserving of acquisition by future generations.

Once settled, the idea of invoking the intervention in sub-national government intervention clause without a normatively created process that propels the habit of legality, will entrench a government that exercises unlimited arbitrariness and viciousness (mostly political), and unrestrained by any legal guarantees. The evaporation of established legal norms such as the audi alteram partem rule becomes the first indicators of the development of the power of doing public good without rules, which is the very first step towards despotical power; the sovereignty of the individual in law becomes thus the greatest casualty as focus is on the public good at whatever cost. The dictatorial authority that accompanies most sub-national interventions in democracies that don’t have a regulatory mechanism of the process, often occur when there is an overinflated perception of benevolence in the incumbent leadership, or a growing personality cult.

The experience of past section 100 interventions such as that in the Limpopo Province of South Africa, with striking coincidences of the service delivery departments that spearheaded the intervention, creates a further sieve of the dangers in the currency of perceived benevolence or a misguided insatiable appetite for power by national ministers skilled at manipulating political power vacuums. The then narrative behind the intervention was the ‘apparent bankruptcy’ of the provincial administration. The result was the usurping of executive powers in selected departments with the outcome being the removal of the Premier, and thus facilitating the ultimate dismissal of the ANC Youth League President, who was then the political prize of the intervention. The contestations for the control of executive discretion that accompanied the executive authority of the premier muddied the ‘nobility’ of the intents in intervening. In a normative state where the idea of the law as a constraint is the fulcrum upon which all state decisions are based, the section 100 (3) legislation would have by now been promulgated and an intervention process would have been defined already.

The idea of intervention remains one of the hallmarks of the South African intergovernmental relations system. It provides the necessary checks and balances for a democracy that procures for its political mandate in sub-national jurisdictions thus creating a potential for an ideological discord between the centre and the periphery of government. In coordinating this efficiency, the system has the potential of creating inefficiencies that may manifest themselves in in-party factional tensions being a greater motivation for intervention, when there is no regulatory framework governing the process. The preponderance of regime change tendencies may be exploited into the creation chaotic environments that create a perception of ‘failure to fulfil an executive obligation’ thus triggering a domino that procures for section 100 intervention outside a section 100 (3) and others legislation. The jury remains out on the correctness of the Limpopo and North West interventions respectively. It is the extent to which that intervention was normative or prerogative that will pronounce on the despotical or otherwise of the ruling centre. 

Whilst section 100 is a necessary clause in the architecture of the South African intergovernmental relations system, it remains a prerogative state building provision unless it is somehow regulated by further legislation. The context at which it was drafted, like many legislations in South Africa, assumes the continued existence of the Mandela benevolence and does not anticipate a possible despotical environment that may be created by successors of Mandela. The shenanigans around the Mayor of Cape Town further indicate that the risk is not only in-ANC based. The repugnancy provisions that are designed to keep national economic unity and national interest remain the pillars with which the section 100 provisions would always be justified with. However, the political reasons often perceived to be at play when the section is invoked, makes the nobility of its intents to be profoundly compromised. The question is therefore, is the section promoting a prerogative way of running a state or a normative way of dealing with sub-national challenges. The question is, can this section be applied in a jurisdiction governed by an opposition party; in there lies its normativity or otherwise. It is therefore important for government to manage how it communicates the issue of reviewing sub-national governance, particularly interventions. Centralisation of political power has joined the absence of the rule of law as fundamental considerations for foreign direct investment in a country. With the current global economic meltdown investors are increasingly paying attention to the political management of economies, with a particular focus on sub-national ‘governments’ as primary units of democratic expression. The global decentralist movement has continuously been gaining premium because of the failure of centrally managed political economic decisions by either governments or recession responsible private sector multi-national firms.




[1] Meierhrnrich, J. 2008. The Legacies of Law.

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