MOKGORO J proportionality between the effect of the legislative measure and its purpose was not met: The aims of promoting professionalism and preventing irresponsible and misleading advertising . . . do not require the exclusion of much of the speech which is prohibited by [the statute].”86 [50] In Coetzee v Government of the Republic of South Africa; Matiso v Commanding Officer, Port Elizabeth Prison, wherein this Court held a statutory provision providing for imprisonment in certain circumstances of nonpayment of civil debts to be unconstitutional on the ground, inter alia, that such provision was overbroad, the Court held that while providing a mechanism for the enforcement of judgment debts was a reasonable and legitimate governmental objective: [T]he question . . . is whether the means to achieve the goal are reasonable. In my view, the answer is clearly in the negative. . . The fundamental reason why the means are not reasonable is because the provisions are overbroad. The sanction of imprisonment is . . . aimed at the debtor who will not pay. But it is unreasonable in that it also strikes at those who cannot pay and simply fail to prove this at a hearing . . .87. [51] While striking down parliamentary statutes as void for overbreadth may be new in South Africa, because courts lacked the power to do so under a system of parliamentary sovereignty, a similar method of analysis was applied in the course of testing subordinate legislation for ultra vires. Subordinate legislation was invalidated on the basis that the means used exceeded the limits implied by the underlying objectives of the empowering statute. For example, in United Democratic Front v State President,88 the court sustained in part a challenge to emergency regulations promulgated under the Internal Security Act. The regulations defined a “subversive 86 Id. 81. The Indian Supreme Court has adopted a broadly similar analysis: “There must be a direct and proximate nexus or reasonable connection between the restriction imposed and the object which is sought to be achieved.” Pathumma v State of Kerala, [1978] (2) S.C.R. 537, 549. 87 1995 (10) BCLR 1382 (CC) 1391 (per Kriegler, J.) 88 1987 (3) SA 296 (N). 29