In South Africa, while excessive, deadly, or lethal use of force tends to be associated more often with the SAPS, private security officers have also been guilty of such activities. This connotation to the SAPS, has largely been driven by public perceptions, formed in part by media reporting on public and high-profile use of force incidents such as the death of Andries Tatane and the shooting of the striking Marikana miners. The incidents of use of force by private security officers in South Africa tend to be overlooked, and less reported, as they do not occur frequently or have far less loss of life associated with them. They are often accused of, 'irregular 'arrests' of undocumented foreign migrants, vagrants or alleged suspicious acting persons in public spaces in residential areas or public streets. With reference to the above case study, demonstrate and debate your understanding regarding the South African Legislation on the use of force on arrest, up to and including, the discussion of the Constitutional Court judgement in May 2002. Eventually, on 21 May 2002, which found that s49(2) authorised the use of deadly force for arrests in circumstances that are so wide as to be constitutionally unjustifiable. For example, an arrest for a trivial offence, such as shoplifting, where the unarmed suspect could be shot while either resisting arrest or fleeing or for a serious but non-violent one such as fraud (Ex parte Minister, 2002). (20)