90 | Zimbabwe Rule of Law Journal on this aspect. However, South African Courts have established that this factor looks at the effects of the limitation on the right concerned and not on the right holder.126 In the context of this paper, what is the effect of the limitation on the right to use an official language? The law that limits the right should not do more damage to the right than is reasonable for achieving its purpose.127 The fourth factor is the relationship between the limitation and its purpose. Section 86(2)(b) qualifies this factor to assess whether the limitation “... imposes greater restrictions on the right or freedom concerned than are necessary to achieve its purpose.” The fifth factor concerns the availability of less restrictive means to achieve the stated purpose. South African Courts have established that the limitation is not be proportional if there are less restrictive (but equally effective) means that can be employed to achieve the same purpose of the limitation.128 The sixth factor is the need to ensure that the enjoyment of rights and freedoms by any person does not prejudice the rights and freedoms of others. Clearly, s 86 incorporates the principle of proportionality. Pretorius’129 argues that the application of proportionality to s 6 demands in general that the principle of inclusive linguistic diversity expressed in the official language clause must be related to other competing values, principles or considerations in a way which is non-reductionist130 and non-hierarchical.131 126 S v Meaker 1998 8 BCLR 1038 (W). 127 S v Manamela 2000 3 SA 1 (CC) 34. 128 S v Makwanyane 1995 3 SA 391 [123] and [128]. 129 JL Pretorius‘The Use of Official Languages Act: Diversity affirmed?’ 2013(16)1 PER / PELJ 281 282 299. 130 Non-reductionism requires that competing constitutional goods should be related to one another in a way which preserves their plurality without reducing one into another and without lumping all of them together into some common space (like utility) that denies their plurality. 131 Non-hierarchical relatedness means that constitutional goods must not be pitched against each other in terms of an arbitrary abstract rank order.