O’REGAN J and SACHS J which safeguard individual freedom are protected by their Constitution.42 O’Connor J too distinguished in a similar manner between zones of protected activity and others.43 Central to the reasoning of both Brennan J and O’Connor J is the concept of a zone of privacy that diminishes as the activity becomes more public in character. This notion has been foundational to this Court’s jurisprudence on privacy. [80] The problem in the present matter is where to place commercial sex on the continuum described by Ackermann J in Bernstein. In doing so, it is necessary to realise that there are a range of factors relevant to distinguishing the core of privacy from its penumbra. One of the considerations is the nature of the relationship concerned: an invasion of the relationship between partners, or parent and child, or other intimate, meaningful and intensely personal relationships will be a strong indication of a violation close to the core of privacy. Another consideration is the extent to which the body of a person is invaded: physical searches or examinations are often invasive of privacy as section 13 of the interim Constitution suggests. 42 Id at 617-8. 43 Id at 631 and 636. 52