MOGOENG J Introduction [1] This is an application for leave to appeal against the judgment of the Supreme Court of Appeal.1 It raises the question whether the Minister of Safety and Security2 (Minister) should be held vicariously liable for damages arising from the brutal rape of a thirteen year old girl by a policeman who was on standby duty. [2] In the determination of that question, the state‘s constitutional obligations to respect, protect and promote the citizen‘s right to dignity, and to freedom and security of the person3 would have to be taken into account. Equally relevant is the state‘s establishment of a police service for the efficient execution of its constitutional obligations to prevent, combat and investigate crime, to protect and secure the inhabitants of the Republic and their property, and to uphold and enforce the law.4 [3] The trust that the public is entitled to repose in the police also has a critical role to play in the determination of the Minister‘s vicarious liability in this matter. [4] In the event of the Minister being held liable, it would be necessary to ensure that that decision does not effectively give rise to state liability for all delictual acts committed by the police. 1 Minister of Safety and Security v F 2011 (3) SA 487 (SCA) (SCA judgment). 2 The Minister of Safety and Security, as cited in these proceedings, has been renamed the Minister for Police. 3 Sections 10 and 12 of the Constitution. 4 Section 205(2) and (3) of the Constitution. 2