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[SUBMISSION] SERI, ICF and Abahlali make a submission on the White Paper on Human Settlements (15 March 2024).

White Paper on Human Settlements SERI ICF submission coverOn Friday, 15 March 2024, the Socio-Economic Rights Institute (SERI), Inner City Federation (ICF) and Abahlali baseMjondolo made a submission to the Department of Human Settlements on the White Paper on Human Settlements in line with its call for comment issued on 18 December 2023.

Overall, SERI, ICF and Abahlali welcome the housing rights framing in the General Principles of the White Paper, and support the positions on prioritising informal settlement upgrading and on rental housing, as well as the assertion that rapid land release is a pro-active mechanism for pre-empting occupations. However, as noted in the submission, SERI, ICF and Abahlali raise several concerns and offered recommendations for changes. These concerns include:

  • The consultation process, the notice period in particular, has been flawed, leading to an inability on the part of organisations to consult with their members and constituencies.
  • People need to be centred in the White Paper, and the measures taken to secure a home, in the context of unrelenting poverty, should be identified and acknowledged, in order to treat people with the respect and dignity deserving of all human beings.
  • The historical review in the White Paper is incomplete.
  • The White Paper's problem statement is underdeveloped.
  • The housing rights commitment is not followed through and in some places is subverted.
  • The White Paper does not develop an analysis of women’s unequal access to housing rights and as a result women’s equal access is inadequately treated in the proposals.
  • The White Paper is silent on the rights of migrants.

Finally, SERI, ICF and Abahlali submit that the White Paper is incomplete in its rights framing, especially with regard to land and tenure rights, and rights to basic services, which all fit within the ambit of “human settlements”, as defined in the White Paper.


  • Access the submission here.