activity of national courts. The basis for this has been established through the constitutionalisation of economic, social and cultural rights (ESCR) through one of two means: as "directive principles" that are goals and are often non-justiciable; or as expressly protected and enforceable through the courts. South Africa In South Africa, the right to water is enshrined in the constitution and implemented by ordinary statutes. This is evidence of a slight modification of the second technique of constitutionalisation referred to as the "subsidiary legislation model". This means that a large portion of the content and implementation of the right is done an ordinary domestic statute with some constitutional standing. Residents of Bon Vista Mansions v. Southern Metropolitan Local Council The first notable case in which the courts did so was the Residents of Bon Vista Mansions v. Southern Metropolitan Local Council. The case was brought by residents of a block of flats (Bon Vista Mansions), following the disconnection of the water supply by the local Council, resulting from the failure to pay water charges. The court held that in adherence to the South African Constitution, that constitutionally all persons ought to have access to water as a right. Further reasoning for the decision was based on General Comment 12 on the Right to Food, made by the UN Committee on Economic, Social and Cultural Rights imposing upon parties to the agreement the obligation to observe and respect already existing access to adequate food by not implementing any encroaching measures. The court found that the discontinuation of the existing water source, which had not adhered to the "fair and reasonable" requirements of the South African Water Services Act, was illegal. It is important to note that the decision pre-dates the adoption of the UN General Comment No. 15. Mazibuko v. City of Johannesburg The quantity of water to be provided was further discussed in Mazibuko v. City of Johannesburg. The case revolved around the distribution of water through pipes to Phiri, one of the oldest areas of Soweto. This case concerned two major issues: whether or not the city's policy regarding the supply of free basic water, 6 kilolitres per month to each account holder in the city was in conflict with Section 27 of the South African Constitution or Section 11 of the Water Services Act. The second issue being whether or not the installation of pre-paid water meters was lawful.