2. With reference to your call for submissions as published on www.parliament.gov.za, the CFCR welcomes the opportunity to make concise submissions to the Committee regarding the Public Administration Management Bill [B55B-2013](the Bill) and certain aspects of the Bill that we believe require revision or amendment.
3. It is hence not the purpose or intention of this submission to provide a comprehensive legal analysis of the Bill and all matters related thereto, but rather to draw attention to those aspects and clauses which, in context of those constitutional provisions relevant to public administration, may not be consistent with the Constitution.
4. The CFCR welcomes, in principle, legislation which, as required by section 195(3) of the Constitution, gives effect to the values and principles provided for in section 195(1). However, at the outset, it is important to note that considering the purpose and scope of section 195 of the Constitution, the proposed Bill appears to be limiting the application of section 195 due to a restricted and insufficient definition of “public administration”.