Inthuthuko Means That We Are Going Forward: Hearing the Voices of Domestic Workers in South Africa


"INTHUTHUKO MEANS THAT WE ARE
GOING FORWARD": HEARING THE
VOICES OF DOMESTIC WORKERS
IN SOUTH AFRICA

Melissa Cole*

INTRODUCTION

Just as law itself, in trying to speak for all persons, ends up silencing
those without power, feminist legal theory is in danger of silencing
those who have traditionally been kept from speaking, or who
have been ignored when they spoke ....

In May of 1991, I was caught up in the last-minute preparations for
spending my summer in South Africa on a human rights internship.2

While much of the preparation involved the details of a visa and plane
tickets, the most important part revolved around planning for the work I
would do there and deciding just what I wanted to take out of it. I had
chosen to work with the Black Sash Legal Advice Office in Johannesburg 3

because I knew it would provide me the opportunity to speak directly with
African" women, to find out what they faced, how they felt, what they
hoped to change in their lives, and how they hoped to effect that change.
This information, I decided, would form the basis for an article on the
conditions of African women in South Africa.

* Melissa Cole received her A.B. in American Civilization from Brown
University in 1988 and expects to receive her J.D. from Columbia University School
of Law in 1993. She hopes to continue to work with international human rights and
especially with women's rights.

Angela P. Harris, Race and Essentialism in Feminist Legal Theory, 42 Stan.
L. Rev. 581, 585 (1990).

2 I am indebted to Sheena Duncan for setting up the internship for me and for
welcoming me to South Africa, as well as to the Columbia Human Rights Internship
Program for funding my work.

Black Sash is an anti-apartheid group founded by white women which is heav-
ily involved in political protest. The group currently operates a number of Legal
Advice Offices, where a staff of varied ethnic backgrounds provides free services
and referrals to anyone wishing assistance.

' I choose the designation "African," as opposed to "Black," because it empha-
sizes that Africans are people of Africa and best encompasses the cultural experi-
ences of the women. The designation is also separate from the South African
"apartheid" classifications based purely on skin color.



Columbia Journal of Gender and Law

However, when I told people about my plans I found the same

questions being thrown at me again and again. "How can you expect to
know them after just ten weeks?" "How can you purport to speak for

women whose backgrounds and experiences are so different from your
own?"

These questions made me stop and think hard about my proposal. As

a white, middle-class woman, I felt in some ways barred from meaningful

contribution to the discussions of race and class occupying much current
writing in feminist jurisprudence. At the same time, I realized that, despite

my best intentions for contributing to change, it would be insensitive of me
to charge ahead without acknowledging the limits of my perspective.5

Finally, I boarded the plane for Johannesburg with a more open mind

and a desire to speak to as many women there as possible in order to hear
firsthand what their lives were like. At the Advice Office, I counseled

domestic workers only, because the great majority of the women who
come to the offices,6 as well as the largest number of urban African working
women in South Africa, are employed in domestic work.7 My paper

therefore focuses on their experiences as especially illustrative of the
various limitations and frustrations of life for African women in South
Africa.

In addition to my work as a counselor at the office, I spent a great deal

of time in South Africa researching the conditions under which the women
live. This research provides both a context for their stories and an
illustration of the "difference" that separates us. However, such secondary

5 In the writing and editing of this piece I discovered the additional limitations
of language, which is subject not only to the author's intentions, over which I had
control, but also to the reader's inferences, which my editors tried to help me
address. The very question of whether I could in theory write a paper about
African women was mirrored in the question of whether I was able to choose the
appropriate words to do so.

6 Domestic workers accounted for 13% of all cases seen in the Johannesburg
office in 1990, a total of 666 cases, or 2 to 3 each day. Johannesburg Advice Office
Report 2 (1990). Of the 345 small claims court cases brought with the help of
Black Sash's Johannesburg office between January 1 and August 8, 1991, 294,
about 85.2%, were on behalf of domestic workers wrongfully dismissed. Black Sash
Small Claims Court Files (1991) (on file with Black Sash).

7 In 1982,50% of African women in South Africa were employed in services,
including domestic service. In contrast, 11% were employed in the professional sec-
tor, mainly nursing and teaching; 3% in clerical jobs; 5% in sales; 17% in agricul-
tural production; 13% in manufacturing. Jacklyn Cock, Maids and Madams:
Domestic Workers Under Apartheid 7 (1989).

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Hearing the Voices

statistics about domestic workers' lives also tend to present them as a
monolithic group and, in the process, to dehumanize them. Ironically, the
actual conditions imposed upon domestic workers by their white employers
and a white minority government seem directed at doing just that. My
presentation of secondary information serves to illustrate how these
conditions may be seen as an attempt to dehumanize domestic workers.

Upon returning to the United States, I took a closer look at the debate
within American and Canadian feminist jurisprudence between an
essentialism that assumes a common "woman's experience" and the
growing call for recognizing differences among women and putting an end
to the middle-class, white appropriation of the feminist movement. I
found that the need for a middle ground was clear and agreed upon, but
the means of achieving it seemed murky.

It occurred to me, as I investigated this debate, that the common
experiences of womanhood, while not an entirely unifying force, do
establish connections between people of different backgrounds. I realized
that I, a white, middle-class, American woman, may have been through
some single event, at a level beyond race, class, and any other perspective,
that prompted the same human emotions that an African, working-class,
South African woman may also have felt through her experiences. Thinking
back on our conversations, I saw that the experiences shared at this level
made communication between us possible. The events that prompt these
shared emotions I refer to as "common experiences" or "connections."

This paper therefore presents the thoughts and goals of domestic
workers in their own voices. In consciously trying to avoid the replacement
of their voices with my own paraphrasing and analysis, I hope to provide
the reader with the means of establishing a connection on a basic, emotional
level and thus to discover a common experience with the women speaking.
In this way, I mean to illustrate how the debate within American and
Canadian feminist jurisprudence, with its advocates of global feminism,8

may avoid the pitfalls of both essentialism and difference and move toward
communication, understanding, and solidarity.

I begin this paper, then, with a presentation of the debate between
essentialism and difference within American and Canadian feminist
jurisprudence. I then present domestic workers' stories about their
circumstances, supplementing their narratives in deliberately separate
sections with contextual information on the living and working conditions
of domestic workers as a group. Finally, I examine their agendas for
change, accompanied by a note on other African women's agendas as a

' For aspects of global feminism, see generally Sisterhood Is Global: The
International Women's Movement Anthology (Robin Morgan ed., 1984).

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Columbia Journal of Gender and Law

reminder that women as a group are mobilizing. Although initially hesitant
about mixing the voices and the secondary facts, I found that their
juxtaposition highlights the overriding theme of this article-that while the
secondary information points out our differences, the human voices may
accent our connections.

THE ESSENTIAL WOMAN FRAGMENTED BY DIFFERENCE

The Conflict

In seeking a voice within legal theory and an articulation of those
concerns ignored by the dominant legal discourse, American and Canadian
feminist juxisprudence scholars find themselves at the proverbial
crossroads. On the one side they may settle into the "welcoming" arms of
essentialism and find themselves accepted simply by virtue of their
womanhood. Turning the other way, they delve into the multiple facets of
their own individual experiences not only as women, but as women of color,
lesbians, working-class women, physically challenged women-and an
endless variety of other self-classifications.' While many women yearn for
some middle road, few practical suggestions exist for building one. Scholars
tend to choose one path or the other, though they may also choose to stay
close to the side of one road in an attempt to venture closer to the other."

The scholar who chooses the path of essentialism joins the pioneers of
feminist jurisprudence in recognizing difference primarily along gender
lines. Focusing on women's difference from men, she assumes a shared
connection with all women. She enters the world of Catharine MacKinnon,

I I by no means intend this list to be all-inclusive, nor do I believe that I could
create an all-inclusive list. Instead, I refer to "self-classifications" because this term
embraces the two most important characteristics of identities such as Black, lesbian,
physically challenged, etc., that is, that groups are identified along such lines and
that women who speak from the points of view of membership in such groups are
aligned with the groups' identities. While they may not initially choose to include
themselves in the group, but find themselves classified by society or the actions of
others, their choice to speak from a particular perspective indicates a conscious deci-
sion to define their experience as that of a member of the group. That decision
becomes a self-definition.

10 While the picture of these two roads may suggest that feminist jurisprudence
scholars deliberately choose one path to the exclusion of the other, such is not the
case. Indeed, many women now write of the need to establish a middle ground that
avoids movement only in one direction or the other. See infra notes 22-37 and
accompanying text. However, the middle road has not yet been adequately con-
structed, and I therefore present a picture of the two distinct avenues.

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Hearing the Voices

who, in her concentration on laws governing rape, pornography, and
sexual harassment," defines "equality" as being the same as men,
"difference" as the lack of correspondence with male standards, and
"gender neutrality" as just such a male standard.' MacKinnon's view
that laws on sexual discrimination affect women's "chance at productive
lives of reasonable physical security, self-expression, individuation, minimal
respect, and human dignity" "across class lines" 13 recognizes that women
belong to different economic classes but contends that class differences may
be subsumed in discrimination against women as a whole."

Wandering further down the essentialism path, the scholar encounters
Robin West's "connection theory" and discovers that her womanhood
means she is "actually or potentially materially connected to other human
life . . . [in a way that men] aren't." s She further discovers that some

branches of feminism are unified in "the discovery, or rediscovery, of the
importance of women's fundamental material difference from men." 16

However, the woman who heads in a different direction finds herself
acknowledging the existence of issues that differentiate individuals within
their own gender, issues such as race, class, culture, sexual preference,
physical challenge, religion, nationality, and so forth. She joins in the
"critique of blindness to difference within difference" 7 and finds herself in
the company of bell hooks, "calling attention to interlocking systems of

" See Catharine A. MacKinnon, Sexual Harassment of Working Women
(1979); Catharine A. MacKinnon, Feminism, Marxism, Method, and the State: An
Agenda for Theory, 7 Signs 515 (1982); Catharine A. MacKinnon, Feminism,
Marxism, Method, and the State: Toward Feminist Jurisprudence, 8 Signs 635
(1983). See generally Fred Strebeigh, Defining Law on the Feminist Frontier, N.Y.
Times, Oct. 6, 1991, § 6 (Magazine), at 28 (discussing MacKinnon's work and areas
of impact).

12 Catharine A. MacKinnon, Legal Perspectives on Sexual Difference, in
Theoretical Perspectives on Sexual Difference 213, 214-18 (Deborah L. Rhode ed.,
1990).

13 Id. at 215.
"' For criticism of MacKinnon's approach as essentialist, see Harris, supra

note 1, at 591 ("As a political matter..., MacKinnon is quick to insist that there is
only one 'true,' "unmodified' feminism: that which analyzes women as women, not
as subsets of some other group."); Marlee Kline, Race, Racism, and Feminist Legal
Theory, 12 Harv. Women's L.J. 115, 134-44 (1989).

5 Robin West, Jurisprudence and Gender, 55 U. Chi. L. Rev. 1, 14 (1988).
1 Id. at 14. For a criticism of West's essentialist approach, see Harris, supra

note 1, at 603. Harris calls "West's claims... clearly questionable on their face inso-
far as the experience of women-'mothers'-is asserted to stand for the experience
of all women." Id.

" Brenda Cossman, A Matter of Difference: Domestic Contracts and Gender
Equality, 28 Osgoode Hall L.J. 303, 350 (1990).

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domination-sex, race, and class-[so that] Black women and many other
groups of women acknowledge the diversity and complexity of female
experience, of our relationship to power and domination.""8 She recognizes
that "racism and class elitism among women have frequently led to the
suppression and distortion of [the shared ideological foundation between
patriarchy and other forms of oppression] so that it is now necessary for
feminist thinkers to critique and revise much feminist theory and the
direction of the feminist movement." 9

The difference scholar joins John Dupr( in acknowledging that "there
can be no consistent stopping place for feminist politics short of
comprehensive and systematic resistance to all... forms of oppression.""
Finally, she arrives at the problem presented by Tamsin Lorraine, that
"Idlespite the obvious advantages of a unified perspective for collective
political action, the differences among women disallow such a perspective." 21

Thus, for the woman wishing to move in both directions-a basic
connection with all women coupled with a recognition of the differences
between them-a dilemma arises. While women must work collectively
to achieve change both in social conditions and in legal assumptions, they
are each bound by their own individual experience and therefore find
themselves unable to speak for others without the risk of distorting feminist
concerns. As Marlee Kline points out, "[oiverlooking racial identity... has
the effect of appropriating the pain of specific groups by attributing the
particular experiences of women of color to all women... ."" However,
once women recognize their inability to speak for others they find the
collective fragmented and communication increasingly difficult.

" bell hooks, Feminism: A Transformational Politic, in Theoretical Perspectives
on Sexual Difference, supra note 12, at 187. hooks adds that "[t]he intent is not to
dissuade people of color from becoming engaged in the feminist movement." Id.

Id. at 188.
John Dupr6, Global Versus Local Perspectives on Sexual Difference, in

Theoretical Perspectives on Sexual Difference, supra note 12, at 61.
21 Tamsin E. Lorraine, Gender, Identity, and the Production of Meaning 20

(1990).
" Kline, supra note 14, at 124. Harris warns against the flip side of appropri-

ation, a type of tokenism she terms "nuance theory":

[Bly being sensitive to the notion that different women have different expe-
riences, generalizations can be offered about "all women" while qualify-
ing statements, often in footnotes, supplement[] the general account with
the subtle nuances of experience that "different" women add to the mix.
Nuance theory thus assumes the commonality of all women-differences
are a matter of "context" or "magnitude"; that is, nuance.

Harris, supra note 1, at 595.

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19921 Hearing the Voices

Harris very aptly illustrates this potential fragmentation in her
presentation of a scene in which women of different colors meet to determine
a feminist agenda and their differences cause a breakdown in communication:

White women stress women's commonality, which enables them to
control the group's agenda; black women make reference to 200
years of slavery and argue that their needs should come first.
Eventually, as the group seems ready to splinter into mutually
suspicious and self-righteous factions, someone reminds the group
that after all, women are women and we are all oppressed by men,
and solidarity reappears through the threat of a common enemy. 2

In Harris' scenario, women ultimately return to an essentialist approach,
with its attendant problems of rendering invisible nonwhite, nonprivileged
women while appropriating their voices.24

This conflict within feminist jurisprudence goes beyond a theoretical
debate, for, as Martha Fineman points out, "[fleminists must overcome these
differences [between women] in both practice and theory because the
existence of these differences is misused to divide women."5 She explains
that "Itihe task of feminist theory in this regard is to encourage women to
work together, across differences, so that the similar, shared gendered
aspects of our lives do not continue to be invisible and unspoken in law."26

The challenge, then, is to find a place where essentialism and difference can
meet, where individuals can maintain a connection while preserving the
integrity of their own experiences and the experiences of others.

The Conflict Manifests Itself

To those people trained in European-based legal theories and molded
in traditional classrooms, the debate between essentialism and difference
seems insurmountable. In a world of absolutes and of a language where

2 Harris, supra note 1, at 606.
24 Id. at 607.
" Martha L. Fineman, Challenging Law, Establishing Differences: The Future

of Feminist Legal Scholarship, 42 Fla. L. Rev. 25, 26-27 (1990).
Id. at 27.
By "European-based legal theories" and "traditional classrooms" I mean the

modes of law and legal training employed by most practitioners and most professors
at most law schools in the United States, at least including Columbia University,
which I attend. For constructive views on changing American legal education, see
Patricia A. Cain, Teaching Feminist Legal Theory at Texas: Listening to Difference
and Exploring Connections, 38 J. Legal Educ. 165 (1988); Mari Matsuda, Affirmative
Action and Legal Knowledge: Planting Seeds in Plowed-Up Ground, 11 Harv.
Women's L.J. 1 (1988).



Columbia Journal of Gender and Law

"objectivity" is nebulously defined and fervently believed, the debate
cannot move in a constructive direction, for the language of traditional law
speaks only in the generalities of the "reasonable person"" and prizes its
exclusion of adjectives such as "Black"2 or "lesbian" except in specialized
fact situations.

The exclusion of considerations of difference purports to operate to the
benefit of "others," for "[tihe requirement of fair judging is to treat
individuals without regard to status, race, gender, or class."2' However,
while the judging purports to be fair, the outcomes are often
discriminatory.3' Furthermore, Mari Matsuda points out that

[wihen outsiders' perspectives are ignored in legal scholarship,
not only do we lose important ideas and insights, but we also fail
in our most traditional role as educators. We fail to prepare
future practitioners for effective advocacy and policy formation
in a world populated by women and men of differing points of
view.

2

In striving to create general legal guidelines meant to apply regardless
of a person's individual position, the legal system limits its own ability to
address valid differences in the way individuals perceive and are affected
by society.Y By refusing to recognize an injured plaintiff as working-class
and a defendant as a multimillion dollar corporation, a judge subscribes to
the myth that the $100,000 award means as much to the corporation as it
does to the unemployed worker and suggests that the worker will be
made whole by the award and the company will avoid further

" The designation of a reasonable "person" is deemed by some a great triumph
for feminism, for it supplanted the traditional "man" standard. However, the
change in labeling did little to change the concept underlying the original phrase.
A great deal of scholarship has been devoted to the "reasonable person"-"rea-
sonable woman" debate. See Lucinda Finley, in "Feminist Jurisprudence"-The
1990 Myra Bradwell Day Panel, 1 Colum. J. Gender & L. 17, 19-21 (1991).

2 I have chosen to capitalize "Black," in contrast with "white," in recognition
of the fact that, at least in an American context, "Black" denotes a heritage and iden-
tity more unified than the whiteness of various other Euroethnic groups' skin.

I Judith Resnick, On the Bias: Feminist Reconsiderations of the Aspirations
for Our Judges, 61 S. Cal. L. Rev. 1877, 1903 (1988).

31 Id.
Matsuda, supra note 27, at 4.
These guidelines are inherently biased toward the white, middle-class male

perspective that shaped them. See Resnick, supra note 30, at 1906 ("[W]hat has been
assumed (by some) as a universal viewpoint is, in fact, a viewpoint of some men,
who have articulated a vision of reality and claimed it to be true for us all.").

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Hearing the Voices

wrongdoing.3 In ignoring a criminal defendant's disadvantaged

upbringing, the jury merely condemns her to a term of imprisonment

without addressing the true societal problems that first prompted her to

commit the crime.
So, too, in encouraging feminist jurisprudence to establish one general

set of juridical guidelines written in the language and form of existing legal

concepts, traditional jurisprudence limits our ability to speak effectively

both as a collective and as the distinctive individuals therein. Only by
opening up the law to recognition of personal characteristics' that allow

the establishment of true connections between individuals instead of the

assumption of shared situations and perceptions can feminist jurisprudence
move forward and effect change.

To bridge differences, some feminist theorists advocate the creation of

a "relational self," which "contains the idea that we are situated in relation

to others, and that our relationships with others are partially constitutive

of who we are."' Harris, too, recommends that "feminist theorizing about
twomen' must similarly be strategic and contingent, focusing on

relationships, not essences."" These relationships can best be established

by bringing people's voices into the law, where their experiences can be
heard and where others can listen to what they are saying.

The Conflict Re-Examined

Establishing connections clearly depends upon opening up the law to

the experiences of individuals, for, as Marilyn Frye asserts:

It is an unforgettable, irreversible, and definitive fact of feminist

experience that respect for women's experience/voice/perception/
knowledge, our own and others', is the ground and foundation of

our emancipation-of both the necessity and the possibility of

rewriting, recreating, the world. Thus it is only by a violent

N See, e.g., Boomer v. Atlantic Cement Co., 257 N.E.2d 870 (N.Y. 1970), in which
the court effectively allowed the defendant corporation to continue polluting a res-
idential neighborhood upon the payment of a monetary "permanent damage"
award. The court proceeded as if the money were a significant burden for the
cement company or could compensate for the plaintiffs' polluted air.

3 Harris suggests that such characteristics should be broken down into facets
rather than broad generalities to avoid some of the problems already inherent in
"objective" standards. Harris, supra note 1, at 586. "My suggestion is... that we
make our categories explicitly tentative, relational, and unstable, and that to do so
is all the more important in a discipline like law, where abstraction and 'frozen' cat-
egories are the norm." Id.

6 Cossman, supra note 17, at 357.
1 Harris, supra note 1, at 612.

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dishonesty that we could, or can, fail to give credence to women's
voices-even when they differ wildly and conflict.-

Yet, as legal scholarship currently and traditionally stands, no
mechanism exists for giving voice to differing experiences." Without such
a mechanism, feminist scholars may strive to paint true pictures of people's
needs, but they necessarily filter the experiences of those for whom they
speak through their own perspectives and thus distort the voices of others.

In order to effectively incorporate multiple experiences that allow
women to establish useful connections amongst themselves, the
presentation of these experiences must be firsthand. Therefore, feminist
scholars cannot speak for other people. However, they may provide a forum
in which other people may speak for themselves. Opening up the law to
the voices and personal stories of individuals and cultivating the skill of
listening allow for the true experiences of people to emerge.

Telling the Story with Our Own Voices

I have ploughed, and planted, and gathered into barns and no man
could head me! And ain't I a woman? I could work as much and
eat as much as a man-when I could get it-and bear the lash as
well! And ain't I a woman? I have borne thirteen children and
seen them most all sold off to slavery, and when I cried out with
my mother's grief, none but Jesus heard me! And ain't I a
woman? '

Marilyn Frye, The Possibility of Feminist Theory, in Theoretical Perspectives
on Sexual Difference, supra note 12, at 177.

", Judith Resnick describes the lack of such a mechanism and recounts using
nontraditional reasoning to support her criticism of Judge Robert Bork for his
absence of humanity when she took part in the hearings on his nomination to the
Supreme Court in 1986:

I was struck by how infrequently his commentary and opinions discussed
the facts of the cases, the people, the lives and the pain of the litigants. My
distress at the modes of analysis led me to criticize the nominee on several
grounds, including the failure to speak with requisite particularity and
compassion. In my written statement, I provided no citation for that
request, for I had no learned legal opinion upon which to rely.

Resnick, supra note 30, at 1922. Judge Bork ultimately failed to receive congressional
approval, for reasons other than his failure to "speak with requisite particularity
and compassion."

, Sojourner Truth, Address at Women's Convention in Akron, Ohio (1851),
reprinted in Angela Y. Davis, Women, Race & Class 61 (1981).

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When Sojourner Truth, the only Black woman at a convention on
women's rights," spoke she shared the pain peculiar to her life, as well as
to the lives of other slaves. While she could not have appeared more
different from the white, middle-class women watching, so removed from
her life experiences, Truth's passionate recant of her "mother's grief"
created a connection between herself and her audience. 2 Her speech is
recounted so often because her words express, more precisely than could
any person outside her experience, the pain she felt as a female slave,
while at the same time her voice connects with the parallel pains of other
women's experiences.

Just as Truth asserted a Black woman's experience many years ago,
Regina Austin insists that current feminist jurisprudence scholars of color
should bring their own personal stories into their work. "[T]he experiential
is not to be abandoned by the minority female legal scholar," she warns.
"She must be guided by her life, instincts, sensibility, and politics. The voice
and vision reflected in her work should contain something of the essence
of the culture that she has lived and learned .... 43

Patricia Cain hopes to bring personal stories into the law school
classroom, where they can have the greatest effect in training future
scholars and lawyers to be sensitive to others' stories and open about
their own.

My major pedagogical goal in this part of the course [where they
told stories about their own experiences] was to encourage the
telling of personal stories about what it meant to be female or
male; what it meant to be black, brown, or white; what it meant to
be living in a heterosexist society. The aim was to emphasize that
a person's point of view is naturally determined by that person's
life experiences. I felt that if we failed to articulate the things that
contributed to our point of view, we would all stay in our separate
little circles .... If we talked and listened, we might begin to
stretch ourselves along the scale. And if we were to continue to talk
and listen upon becoming lawyers, we might help to stretch others."

Similarly, outside the classroom, Martha Minow calls for "consciousness
raising," or the "personal reporting of experience in communal settings to

41 Id.
I Furthermore, "[in repeating her question 'Ain't I a woman?' no less than four

times, she exposed the class-bias and racism of the new women's movement....
Sojourner Truth herself was Black-she was an ex-slave-but she was no less a
woman than any of her white sisters at the convention." Id. at 63-64.

Regina Austin, Sapphire Bound!, 1989 Wis. L. Rev. 539, 542-43.
" Cain, supra note 27, at 175.

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explore what has not been said." 5 By bringing together small groups of
women to share their experiences, she hopes to raise the voices of those
women previously silenced.

The Importance of Listening

Naturally, all the personal expression in the world fails to bring the stories
of individuals into law and legal scholarship if no one listens. Cain captures
this danger in her "theory about listening, really listening.... Often when
we listen to others, we pick out the bits of their stories that are like our stories
and discard the rest. That is, we embrace the familiar, the part that is easily
recognized."" If we hear only that to which we are used to listening, the rest,
the unfamiliar, the silenced voices of the true speakers, is ignored.

The cultivation of listening skills therefore becomes as crucial to the
establishment of connections as the incorporation into the law of people's
voices, for

it is not enough that a plurality of women's voices is heard in law.
It is also important that our diverse voices be understood to affect
one another, to intersect and interact. We must seek to understand
this interaction, to modify our past work in light of this knowledge,
and to apply it to the analyses of women's oppression we attempt
in the future.4 7

In calling for "affirmative action in legal scholarship," the presentation
of new and different perspectives, Matsuda points out the requirement of
"new skills of listening."" "The voices bringing new knowledge are
sometimes faint and self-effacing, other times brash and discordant. To the
extent that our past complicity in academic segregation has contributed to
these different tones, we should strive to understand their origin and
listen carefully for the truth they may hide."4'

On Bringing Women's Voices Into the Law

Through the various shared experiences of women, told in their own
voices and heard by other women, relational connections are established
and the solidarity crucial to successful feminist change becomes possible.
As hooks advises, "[wiorking collectively to confront difference, to expand
our awareness of sex, race, and class as interlocking systems of domination,

45 Martha Minow, Feminist Reason: Getting It and Losing It, 38 J. Legal Educ.
47, 51 (1988).

" Cain, supra note 27, at 171.
7 Kiline, supra note 14, at 149.

4 Matsuda, supra note 27, at 7.
"Id.

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1992] Hearing the Voices 73

of the ways we reinforce and perpetuate these structures, is the context in
which we learn the true meaning of solidarity.""°

THE LIVES OF DOMESTIC WORKERS

My Interaction with Domestic Workers

This dilemma of the shortcomings of essentialism and the fragmentation
of difference became acutely clear to me when I first arrived at the Black Sash
Legal Advice Office in Johannesburg. Upon my entrance, I was greeted by
a roomful of people waiting to be seen. Many of them held referral slips from
previous visits. Some women nursed babies; other clients sat patiently,
their only diversion the activity of the office. The crowded room was filled
with faces framed by bright woolen caps and surrounded by a mix of
uniforms, western clothes, and colorful African wraps.

Walking past these people, I was acutely aware of how easily I could
be identified as a staff member. Not only did my skin color set me apart,
but my American clothing suggested I was different even from white
South Africans. I felt so separate from them that I began to feel nervous
about being able to find a connection between us.

But speaking with my clients quickly lightened such fears. Listening
to them tell the stories that follow, I began to understand the unbearable
treatment they endured because jobs are scarce, as well as the feeling of
holding one's pride together inside because no other choice exists. And I
remembered events in my own life that prompted feelings related to what
the women expressed. I urge the reader, in hearing the voices that follow,
to unearth her own shared connections.

A Note on Methodology

Discovering firsthand accounts of how domestic workers view the
social, cultural, and legal conditions that surround them is a difficult task,
for most of the available information presents analysis only. Their position
in South African society contributes to the difficulty-the possibility of
collective action fragmented by solitary working situations, and political
agitation nearly impossible in the face of long working hours. In addition
to a certain shyness I observed when interviewing the women as part of my
Advice Office work, many of them spoke through African interpreters,"' and
their accounts were noticeably streamlined when they were repeated to me.
Similarly, accounts from other sources are also limited by their researchers'

0 hooks, supra note 18, at 190-91.
I owe great thanks to the interpreters of the Johannesburg Black Sash Office

for all their help: Mabel Makgosethe, Mittah Maphike, Bridget Phakathi, and
Adelina Pholosi.



Columbia Journal of Gender and Law

methodologies. Finally, my choice of which stories to present and how to
present them necessarily impacts on their presentation.

My research in this area, then, focuses primarily on three studies
which include many first-person accounts: Jacklyn Cock's Maids and
Madams: Domestic Workers Under Apartheid;' Suzanne Gordon's A Talent for
Tomorrow: Life Stories of South African Servants;-" and Jane Barrett et al.'s
Vukani Makhosikazi: South African Women Speak."' I supplement these
sources with my own interviews and papers written by African women. I
have tried, wherever possible, to present direct quotations from the women
with whom I spoke. However, because many stories were translated to me
and because I had no tape recording equipment, I at times present events
and conversations without using my clients' actual words.

Working Hours

The Stories

"sI work very hard. I must start work at seven o'clock in the

morning and I only finish at 8.30pm after they have finished eating
supper and I have washed up the dishes. Every Friday I have to
work until 10.00pm because my madam had people for supper. On
Saturday nights I have to come in and look after the children
because the madam and master go out. I don't get paid any extra
money for doing it."5 '

-Eldah Mthuludi

s Cock, supra note 7. Cock's study of domestic workers in the Eastern Cape
is somewhat limiting, since most of the comments she receives from domestic
workers are in response to specific questions and therefore may not accurately reflect
the primary concerns of the domestic workers themselves. The stories presented
in her study are told by anonymous speakers.

I Suzanne Gordon, A Talent for Tomorrow: Life Stories of South African
Servants (1985). Gordon's book, in contrast to Cock's, is based on more free-flow-
ing interviews, rather than conforming to a research agenda. It therefore provides
a more accurate means of gauging the issues that are of foremost concern to
domestic workers. For this reason, I rely more heavily upon Gordon's interviews
than Cock's.

-1 Jane Barrett et al., Vukani Makhosikazi: South African Women Speak (1985).
Their book uses women's voices as a supplement to secondary information.

-" I have placed the voices in quotation marks to emphasize the fact that these
words are women speaking, not just blocks of text. Quotation marks also differ-
entiate between actual voices and my recounts, which are set off by dashes. My pur-
pose in presenting both direct quotes and my own accounts in blocks is to visually
distinguish them from the secondary materials.

-1 Eldah Mthuludi, quoted in Barrett et al., supra note 54, at 29.

[Vol. 2:1



Hearing the Voices

"So much work! Start six in the morning. Breakfasts for everybody,
eggs, coffee, toast. I couldn't take time off in the day. Knock off half
past seven at night."7

-Paulina Masebeso Mokoena

"They went out at half past seven, but I had to be there at six, you
see. They going to tell me what to do and all things like that.
About getting home at night, Mrs[.] Philpson didn't think about
that. I didn't go until I had to finish everything she wanted me to
do on that day. That means even sometimes I left there at five
o'clock. So I get back to Soweto at half past seven. Get home
late. Go early in the morning. That was very, very hard.

She didn't think about the time you had to go home-she only
thought about the time you had to come to work. She thought
about the work she wants me to do and didn't think about what pay
she's going to give me. She never thought about when it was late
at night-she didn't mind if I got out of their house five or six
o'clock and then I got home after eight. My husband said I'll get
killed because that time it's dark and there's nobody."'

-Elizabeth Nomvula Tshayinca

"You can never get away. You can never have a bit of time for
yourself. I can be eating my lunch and my madam will decide she
wants something from the shops or a cup of tea. I must jump up
and go then-I can't even finish eating. If she calls and I'm doing
something I must still go. I can be cooking or ironing and the
child will cry-and she'll shout 'Flora, Cindy's crying.' She's just
lying on her bed or talking on the phone or her friends are visiting.
I'm working and she's doing nothing but I must always be there."

-Flora Manyono

"There's the baking and they're entertaining a lot, sometimes three
or four times a week, even on Sundays. When you're in you knock
off about half past ten, quarter to eleven on Sundays. During the
week, even if they haven't got visitors, it's half past nine. I start at

Paulina Masebeso Mokoena, quoted in Gordon, supra note 53, at 108.
Elizabeth Nomvula Tshayinca, quoted in id. at 74.
Flora Manyono, quoted in Barrett et al., supra note 54, at 30.

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Columbia Journal of Gender and Law

a quarter past six in the morning. Yesterday I only got about
fifteen minutes in the afternoon to rest. If I say anything to Mrs[.]
Goldman she tells me, 'You must never answer me back because I'm
the owner of the house. You must just keep quiet.'" *°

-Christine Mashadi Kgapola

"They take me to the sea and when we get back they say did you
have a good holiday. But it's no holiday for me.""

- Bokhana Elizabeth L. came to the Black Sash Legal Advice Office
and told me of accompanying her employers to Namibia on their
vacation to dean house for their son there. She was stabbed by a man
on the street while working for them. After several weeks of recovery,
she was dismissed for refusing to move heavy furniture because she
was still too weak. 3 Her employer called the trip to Namibia "a
vacation" for her employee, adding that "she didn't pay a cent."-"

The Statistics

The domestic workers I saw started work as early as 6:30 a.m. and
finished as late as 8:30 p.m. (both of these extremes were the same worker).
Michael Whisson and William Weil found that a domestic worker may be
"on duty for anything up to 80 hours per week and [sleep] in her employer's
kitchen or servant's quarters."' Cock discovered that the working hours
of the women she questioned ranged from forty to eighty-five hours per
week with 77.7% working more than a forty-eight-hour week. Nearly one-
third of the total sample work a seven-day week."6 In her study, "[tihe worst
case started work at 6 a.m. and went off around 9 p.m. six nights a week."6 7

In contrast, "[miost [nondomestic] workers in South Africa work between
forty and forty-five hours a week and expect at least two weeks paid
holiday annually.""

60 Christine Mashadi Kgapola, quoted in Gordon, supra note 53, at 217-28.
6 Anonymous speaker, quoted in Cock, supra note 7, at 34.
'3 See supra note 55.

Interview with Bokhana Elizabeth L. in Johannesburg (June 25, 1991).
Telephone Interview with employer of Bokhana Elizabeth L. (June 26,1991).

'3 Michael G. Whisson & William Weil, Domestic Servants: A Microcosm of
"The Race Problem" 39 (1971).

'3 Cock, supra note 7, at 150.
Id. at 127.
Id. at 31.

[Vol. 2:1



Hearing the Voices

When one takes into account the hours live-out domestic workers
spend traveling to and from work and the hours during which live-in
workers are unofficially "on-call," their time spent working increases
greatly and their opportunity for social and home lives becomes almost
nonexistent. As Cock points out, "[a] living-in domestic worker in the
Eastern Cape is frequently considered generally available in the evenings
to cook, wash up, babysit, serve snacks when her employers return from
an evening out or, as in one case, serve coffee at 11 p.m. to their bridge
guests."" She hypothesizes that for those who live out, "it is possible
that domestic workers, because of the distance between black and white
residential areas, have to spend longer [commuting than other workers]." 70

Few workers receive annual leave or public holidays, and for many a
"holiday" means accompanying their employers on their vacation to
provide domestic services. In Cock's study, eighty-three percent of the
workers had to work on public holidays, and twenty-three percent received
no annual holiday. Of the women who did receive annual holidays, only
forty percent received pay during that time.71

These conditions are all perfectly legal because domestic workers are
specifically excluded from the Basic Conditions of Employment Act 7 -
which regulates maximum hours, meal intervals, annual leave, sick leave,
and contract provisions-as well as the Labour Relations Act,"2 which
creates a Manpower Commission, industrial courts, and an industrial
council to settle labor disputes and violations, and which provides inspectors
to ensure that proper working conditions as specified are being met.74

Domestic workers' only means of shortening their hours are to refuse to take
jobs with such demands and thus to risk no employment at all.

In light of the extremely long hours women spend working, it seems
all the more tragic that "[ojn the whole, the more hours that one works for
an employer, the lower the rate of remuneration."'

Id. at 32.
o Id. at 33.
" Id. at 150.
7 Act No. 3, § 1(2)(c) (1983), as amended by Act No. 27 of 1984.
" Act No. 28, § 2(2) (1956), as substituted by Act No. 83 of 1988.
14 Despite the recognized need for protective legislation, some people feel

that incorporation into the Acts would deprive domestic workers of some advan-
tages, such as one month's notice pay upon immediate dismissal, which they cur-
rently receive under common law. Some people recommend special legislation for
domestic workers. See Domestic Worker Submissions to the Centre for Applied
Legal Studies (CALS) (advocating for inclusion in several acts as well as other legal
reforms); Memorandum from CALS to Minister of Manpower Utilisation (recom-
mending a Domestic Servants Act and inclusion in other acts) (both on file with
CALS, Johannesburg).

I Whisson & Weil, supra note 65, at 14.

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Columbia Journal of Gender and Law

The Wages Received

The Stories

"They've got money, they're millionaires, but they don't want to
pay .... I know the Robertsons are exploiting me because they're
underpaying me. I get R150 [about $55.50] a month and R30 [about
$11] for food. Granny eats chops and steak and vegetables, but I go
to Woolworths and buy bones and bring them home for my meals."'

-Muriel Margaret Stella Mlebuka

"There was so much to do with it. A little must go to my mother,
a little must pay for my clothing and a little must pay for my two
sisters' education. Really, it's unbelievable!.. . One month I would
buy something for one sister, the following for the other sister
and the next month for my mother, whatever was needed. The
other month I would get myself something to wear. A pair of
shoes would cost about twelve bob, a good pair, you know. But that
one pound ten shillings was too little. I don't know how the
whites really felt when they gave a worker that money.""

-Thokozile Virginia Mngoma

"I'm getting tired to work for this little bit of money for eleven
years."'

-Abie Begwapi Socatsha

"[If I ask for a raise] [tihe madam will say, 'Nanny, you know the
boss is sick and has to go and lie in hospital and have this operation
and pay all this money.' She will say this to me. I know they got
lots of money, but they got no money for me.""

-Rachel Lydia Ndabezitha

"When I say to the madam, can't you give me more money, the
madam says she is suffering because her children are still at school.

I Muriel Margaret Stella Mlebuka, quoted in Gordon, supra note 53, at 146.
7 Thokozile Virginia Mngoma, quoted in id. at 97.

Abie Begwapi Socatsha, quoted in id. at 139.
" Rachel Lydia Ndabezitha, quoted in id. at 122.

[Vol. 2:1



Hearing the Voices

She hasn't got more money to give me. It is not enough because all
things are dear. It is not enough."'

-Miriam Sindiwe Ngulube

"I always wait until she gives me an increase. Once when I tried
to ask for an increase she told me in a low voice that I must never
ask for an increase. I must just wait, because her husband never
asked for an increase when he was employed by other people.""

"I was told I must never ask for an increase because her husband
does not ask for an increase at Fort England."82

The Statistics

Domestic workers are among the lowest paid workers in South Africa,
and many are paid below the rate given to people qualifying for state
pensions.' The women with whom I worked reported a range of monthly
salaries from R50 [about $18.50] to R400 [about $1451, and an average
salary of R232 [about $861 per month. Few are given or ask for wage
increases, and if they do ask, they are often denied or simply dismissed.

Again, they have no legal recourse for these conditions. Just as they
are excluded from the Basic Conditions of Employment Act and the Labour
Relations Act, domestic workers are similarly excluded from the Wage Act,"
which establishes a wage board to determine minimum wages in covered
job categories.

The Wages Not Received

The Stories

'"Today when I want to get my wages, she say I get my wages in my
fucking ass.""

-Siebongile Pauline N.

'0 Miriam Sindiwe Ngulube, quoted in id. at 168.
Anonymous speaker, quoted in Cock, supra note 7, at 22.

12 Id.
I Marj Brown, Conditions of Domestic Workers 3 (July 1990) (unpublished

report, on file with Black Sash).
" Act No. 5, § 2(2) (1957), as amended by Act No. 58 of 1981 and Act No. 26 of

1984.
' Interview with Siebongile Pauline N. in Johannesburg (Aug. 6, 1991).

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Columbia Journal of Gender and Law

-After working for two months with a promised wage of R190
[about $70], Triphina S. came to me because she had received no
wages at all. Unfortunately, she did not know her employer's
name or correct address and was afraid to return there, so she
was without recourse.- '

-Bolayi Maggy M. and Rosemary L. both told me that when they
asked for their wages, their employers told them that they had no
money to pay them. - u

-Mmetja Violet L. came to the Black Sash Legal Advice Office
because she had been dismissed for asking for her wages on time,'
while Senani Roselyn A. had been dismissed for asking for her
wages at all.- 8

"What is bad about domestic work is that when you stop working,
everything has stopped. You've got no pension money, you've got
no money for insurance or anything of that sort. Once you've
stopped, everything is stopped. That's why most of the people
work until they get very old. Even if they tell you to come to get
your pension from the government that you get every second
month, it's the very little-you can't pop out with that little bit of
money, especially me now, my rent."'

-Elizabeth Nomvula Tshayinca

"After working for her for nineteen years. Promised me a will. The
last of my will was R100 [about $37] from her sister. That's all."9 '

-Bertha Malebone Mabena

The Statistics

Domestic workers' only recourse for the withholding of their wages is
in small claims court. They may learn of this option through the South

" Interview with Triphina S. in Johannesburg (June 2,1991).
u Interviews with Bolayi Maggy M. and Rosemary L. in Johannesburg (June

20, 1991 and Aug. 6, 1991).
" Interview with Mmetja Violet L. in Johannesburg (July 1, 1991).
" Interview with Senani Roselyn A. in Johannesburg (July 16, 1991).
" Elizabeth Nomvula Tshayinca, quoted in Gordon, supra note 53, at 76.
" Bertha Malebone Mabena, quoted in id. at 152.

[Vol. 2:1



Hearing the Voices

African Domestic Workers Union (SADWU) or Black Sash, which relies on
common law rules governing oral contracts to demand notice pay. Many
magistrates of the small claims court are sympathetic, and the rate of
recovery, though not recorded, seems to be high.' However, the actual
damages are very low because they are based on low wages. Furthermore,
not only is filing a claim a lengthy process, but even if a domestic worker
does receive judgment, she may still face yet another lengthy wait to
recover against her former employer.

Few domestic workers have any type of pension to provide for their old
age beyond the meager state pensions given to women once they reach the
age of sixty." Nor do they have any provisions for disability, or for their
families, in the event of their own deaths. According to The Domestic
Pension Fund, fewer than one in one hundred domestic workers have
any of the benefits normally given to industrial and commercial workers.'

Happily, an occasional kind employer will provide retirement benefits
herself. Mamotse Evelyn T. came to me to see whether she had received
everything from her employer to which she was entitled. Her former
employer had agreed to pay her R150 [about $55.50] each month after she
had to retire due to illness. "We didn't fight. We are friends," Mrs. T. said
of her employer.'

Food and Accommodation of the Live-in Worker

The Stories

"Making pudding for them is the worst. I have to just lick the dish
and that's the end." 8

See discussion on SADWU, infra text accompanying notes 241-55.
For wrongfully dismissed workers, Black Sash demands payment through

the end of the month, one month's notice pay, payment in kind for food and
accommodation, and pro rata leave pay.

For a discussion of the use of oral contracts in domestic employment, see the
influential article by Paul Benjamin, The Contract of Employment and Domestic
Workers, 1 Indus. L.J. 187 (1980) (S. Afr.).

" Interview with Phillipa Kruger, University of Witwatersrand Law Clinic, in
Johannesburg (July 19, 1991).

" For a discussion of the inadequacy of government pensions for Africans, see
generally Black Sash National Advice Office, "This Money Will Be Used to Bury Me

.": The Current State of Black Pensions in South Africa (Feb. 1990).
Fedlife, Security in Old Age: The Domestic Pension Fund (brochure, on file

with author). This private plan requires a minimum monthly contribution of R15
[about $5.50] and pays benefits upon retirement between ages 55 and 70, disable-
ment, or death. Id.

' Interview with Mamotse Evelyn T. in Johannesburg (July 25, 1991).
Anonymous speaker, quoted in Cock, supra note 7, at 27.

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Columbia Journal of Gender and Law

"The smell of their food makes me hungry.""

"I only get samp [to eat), but I cook everything and am not allowed
to eat it. Everybody would like a piece of meat, specially if you
have to cook it. The smell is enough."1"

"The only meat I get is what I steal from the pot while the stew is
cooking." 0'

.. . to live on the smell of meat."'

- Bokhana Elizabeth L. told me of the need to spend time with
relatives instead of living in while she was recovering from her
knife wounds because her room at her employer's house was
unheated. - 103

The Statistics

Included in many employers' calculations of wages are "payments in
kind," such as food and accommodation supplied to live-in workers.' °4

However, such food often consists only of "mealie meal," a type of cornmeal
that is made into porridge or "pap," a starchy, filling, bread-like food,
and tea and sugar. In Cock's survey, breakfasts were usually mealie-meal
porridge or bread and jam with tea. Lunch was often mealie meal or
samp, beans and other vegetables, and, "in a small proportion of cases,
meat."105 Indeed, "[ailmost half" of the women in Cock's survey "received
no meat at all." 106 Few of my clients received better food.

Likewise, accommodations are "frequently squalid, or bare and
cramped, especially in comparison with the standard of furnishings in the
employers' living quarters.""° As the stories indicate, the rooms are often
unheated and without electricity, and access to running water may be

"Id.
10 Id.
tm Id.
102 Id. at 16.
10 Interview with Bokhana Elizabeth L. in Johannesburg (June 25, 1991).
'" Black Sash employs a policy of demanding an additional R150 (about

$55.50) per month for food and an equal amount for accommodation as part of the
monthly wages. I found that this practice benefited dismissed workers in enabling
them to demand greater damages.

" Cock, supra note 7, at 129.
0 Id. at 26.
101 Id. at 35.

[Vol. 2:1



19921 Hearing the Voices

limited. Furthermore, these rooms are frequently subject to inspection by
employers." Of course, the rest of the house is reserved for the use of the
employer's family.

On Enduring the Separation from Their Families

The Stories

"You know, before, people didn't mind if you had a baby-say
about six to nine months, you went to work with the baby on your
back. They didn't mind those days, but now some of them don't
want that at all, you see. It's very, very hard.... Some didn't even
want you to pick up the baby, they want you to leave the baby
outside in the yard.""'

-Elizabeth Nomvula Tshayinca

"Now my madam said I can't bring that child here on her property.
She said, why did [your daughter] get that baby? She is naughty.
Now she can't keep that child here on her property because she
was naughty to get the baby. I don't know what I'm going to
do.""

0

-Miriam Sindiwe Ngulube

- Alina Faladi S. came to the Advice Office after her employer
dismissed her because she protested that her one-month-old baby
was too young to be left at home.- "'

- Lungile Mantomsi M. told me that her employer refused to allow
her time off to visit her son in the hospital. As she related the story
to me, she began to cry in fear that her son had already died.- 12

'08 Mmatshilo Kedijang, The Best Kept Secret: Domestic Workers as Victims of
Violence 9 (1990) (unpublished project for the Study of Violence Seminar, Univ. Wis.,
on file with author). Kedijang posits that such searches contribute to the deper-
sonalization of domestic workers. Id.

Elizabeth Nomvula Tshayinca, quoted in Gordon, supra note 53, at 72.
"* Miriam Sindiwe Ngulube, quoted in id. at 169.

Interview with Alina Faladi S. in Johannesburg (July 1, 1991).
112 Interview with Lungile Mantomsi M. in Johannesburg (July 2, 1991).



Columbia Journal of Gender and Law

- Esther M. came to me because she was dismissed for failing to
wash the dishes quickly enough. Her son, who had lived with her
at her employer's house, had elected to stay there with them. - 113

"Seeing a child once a month, it's not enough. It's sad to be
separated from your children while they are still young.", 4

-- Caroline Ramokone Sotloe

"[After coming to visit my daughter in Germiston and finding
that she had been baptized and given a new name without my
knowledge] I cry then and said, why didn't you ask me that you
taking my baby to baptize her in the Church? Why didn't you
baptize the baby with my name? You mean to say that you taking
that baby? That I give you the baby for a present? And then she
tell everybody in Germiston that she's got a baby from a rubbish
girl. She didn't know where to put the baby and she gave the
baby to me for a present. I cry. I go back to work. She wouldn't
give it to me. We'll make the baby to pieces if I take the baby."" 5

-Epsie Mtomkulu Zondo

The Statistics

Of the twenty-four women whom I asked, twenty-one told me of
children living with other family members, some a significant distance from
Johannesburg. Of these women, two clients said their children cared for
themselves, one left her children with a stranger who watched them for pay,
and the rest left their children with husbands, parents, or another family
member. Whisson and Weil found that children often are cared for by their
older siblings, "keeping 12 and 13-year-old daughters out of school in
order to run the home, thus perpetuating the cycle of poverty, inadequate
child care and incomplete education."" 6 Cock found that forty percent of
working African mothers left their children in the care of adult relatives," 7

often in rural areas, which may be distant from their places of employment.
In only half of the cases in Cock's study did the children stay with their

" Interview with Esther M. in Johannesburg (June 19, 1991).
"1 Caroline Ramokone Sotloe, quoted in Gordon, supra note 53, at 197.

Epsie Mtomkulu Zondo, quoted in id. at 24.
116 Whisson & Weil, supra note 65, at 30.
117 Cock, supra note 7, at 10.

[Vol. 2:1



Hearing the Voices

fathers."8 Many employers in Cock's study allowed children to visit, but
she does not report any who allowed the children to live in their houses."'

Those women who do keep their children with them in the townships
are "unable to provide adequate daytime care, [and] the effect of maternal
deprivation for an entire generation of mainly black youth.., has become
a gigantic national problem."" The statistics on child care are daunting.
As of 1986, there were over four million preschool aged African children
in South Africa, but only 0.37% of them were cared for in creches (day

121
nurseries).

Nor is maternity leave a protected right in South Africa.'22 Twenty
percent of the mothers interviewed in a national survey returned to work
when their children were less than two months old, fifty-two percent when
their children were six months old or younger, and sixty-two percent when
their children were one year old or younger."3 Because domestic workers
are not covered by unemployment insurance, 24 many of them, desperately
in need of work, try to hide their pregnancies. Inevitably, of course, the truth
appears and they are dismissed, such as the woman whose employer
angrily told me that her employee had deceived her by lying about her
pregnancy when she was hired. She was subsequently dismissed.

However, the economic realities of supporting a family prevent
domestic workers from leaving those jobs which keep them away from their
children. "All [the women in Cock's study] hate to leave their children
alone during the day or in the care of others, but they are forced to do so
either because they have no other source of income, or because their
husbands do not earn enough to maintain their families." 15 Furthermore,

"I Id. at 43.
Id. at 45.

' Doris Ravenhill, Women and Work in South Africa, Speech at the
International Federation of University Women Study and Programme 5 (1986)
(transcript on file with author).

121 Barrett et al., supra note 54, at 146.
122 Id. at 141. The Wiehahn Commission, sponsored by the government to

report on labor relations, concluded in 1979 that a guaranteed right to return to work
after childbirth "would result in serious complications for employers, especially for
the small employer who has to employ substitute labour when an employee takes
maternity leave and who cannot afford to increase his labour complement by re-
instating the employee concerned." Id. The Commission did, however, recommend
that employers "give cases of this nature their utmost sympathetic consideration
and where possible.., act in the spirit of the recommendation." Id.

12 Id. at 9-10.
124 Id. at 143.

'2 Cock, supra note 7, at 44.

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Columbia Journal of Gender and Law

once she has a family, a domestic worker loses much of her job mobility,
being "less willing to gamble with her work, preferring a regular job to the
possibility of a week or two without employment between jobs, in the hope
of getting a better wage." 12' Ironically, domestic workers are "driven into
domestic employment in order to support their dependents, and then
have to neglect their own families in the process. " 27

In addition to separation from their children, domestic workers must
endure separation from their husbands and other family members., Of the
live-in workers I queried, seven out of eleven were allowed to have their
husbands or boyfriends live with them. However, Cock found that sixty-
four percent of the employers she surveyed did not permit members of the
domestic workers' families to visit them at work. 129 One employer
commented to me that Bokhana Elizabeth L., the woman working for her,
had been "using her room as a hotel for eight years; she's had all her
relatives in." 1 ° What her employer failed to mention was where else Mrs.
L. could visit with her family.

Despite this isolation, when Cock asked the employers in her study if
they thought the workers might be lonely, "all the employers said 'No. '" 13

Domestic Workers' Relationships with Their Employers

The Stories

"The madams are very tough on us. I don't know why because
we're both women....,132

-Elizabeth Nomkhitha Siphika

"She does not see me as a woman. She looks down on me." "

'11 Whisson & Weil, supra note 65, at 28.
'7 Cock, supra note 7, at 20.
" Detention, the practice by which the South African police arrested and

held people without charge, created an additional set of issues for many domestic
workers. For further insight into the impact of detention on the wives of detainees,
see Sue Middleton et al., The Hidden Burden: The Impact of Detention on the
Women Left Behind (unpublished manuscript presented at Black Sash Conference,
Cape Town, on file with author).

129 Cock, supra note 7, at 132.
'30 Telephone Interview with employer of Bokhana Elizabeth L. (June 26,

1991).
"' Cock, supra note 7, at 132.

Elizabeth Nomkhitha Siphika, quoted in Gordon, supra note 53, at 251.
Anonymous speaker, quoted in Cock, supra note 7, at 70.

[Vol. 2:1



Hearing the Voices

"[Tlhey were all right, didn't shout at me or anything, but treated
me like something... something not human, you know.""3 '

-Thokozile Virginia Mngoma

"Once you are employed by them you tend to be a machine that can
be switched on and off which is very wrong: you are still a human
being, you still have feelings of your own. " "

-Margaret Nomgcibelo Nhlapo

"Once you are sick, you are no good for them, they want another
new one. It's just like when something in the kitchen doesn't
work, you just throw it away and you buy a new one. And we are
human beings, just like them. We feel the same. If they are sick, we
look after them. Why can't they look after us?""3

-Catherine Kebuile Kelokilwe

"The cheeky people, when they want you to do something they
never ask you nicely, politely. Say, will you please do this? And can
this be done? Or can you please, today, when you get a chance, to
wash the fridge? They don't say that. All they say is, you must
wash the fridge, or, you must wash the stove and you must clean
the house.""

-Violet Gatote Motlhasedi

"I'm sorry. No matter how you can be, people treat you like dirt.
I didn't know. Had I known, I would have done something for
myself. I did everything for them. I'm sorry, I'm sorry. I never cry,
but somehow, talking about it...

-Muriel Margaret Stella Mlebuka

- Tambisa Hazel N. told me the humiliating story of returning to
her room one day to find her employer's dogs had defecated in it.

'3 Thokozile Virginia Mngoma, quoted in Gordon, supra note 53, at 97.
'3s Margaret Nomgcibelo Nhlapo, quoted in id. at 226.
'3 Catherine Kebuile Kelokilwe, quoted in id. at 175.
'7 Violet Gatote Motlhasedi, quoted in id. at 256.
' Muriel Margaret Stella Mlebuka, quoted in id. at 144.

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Columbia Journal of Gender and Law

"It's enough I share the bathroom with the dogs. But not my room."
She refused to clean it up herself and was therefore called a "kaffir"
[the equivalent of "nigger"] and her wages were docked. - I

"I hate being called 'the girl.' I am 48 years old now and I'm still
a girl.""

-Agnes Ceba

"I take this house as my home, but madam show me that this is not
my home. " "

-Rachel Lydia Ndabezitha

- Mamelato Elisa T. told me she was dismissed because her
employer believed she had stolen a bottle of wine and filled it
with tea. - 142

- Though Gladness L. denied drinking the bottle of whiskey for
which her employer fired her,'4 her employer proclaimed to me
that, "I marked the bottle."- T

4

"My brother in Springs, he phone me on Saturday and she pick up
the phone and the call was for me and she was very cross for me.
She tell me that her phone is not a public phone.""

-Abie Begwapi Socatsha

- Maria Khuri M. was dismissed when her employer accused her
of trying on a dress. However, Mrs. M. told me that the dress was
kept in a locked closet for which she had no key. - I

' Interview with Tambisa Hazel N. in Johannesburg (July 17, 1991).
14 Agnes Ceba, quoted in Barrett et al., supra note 54, at 34.
141 Rachel Lydia Ndabezitha, quoted in Gordon, supra note 53, at 125.
142 Interview with Mamelato Elisa T. in Johannesburg (Aug. 1, 1991).
,3 Interview with Gladness L. in Johannesburg (June 25, 1991).
I" Letter from employer of Gladness L. to author 1 (June 27,1991) (on file with

author).
Abie Begwapi Socatsha, quoted in Gordon, supra note 53, at 136-37.

' Interview with Maria Khuri M. in Johannesburg (July 4, 1991).

[Vol. 2:1



Hearing the Voices

"[My employer is] like a cat. You know, you can play nicely with
a cat, then it scratches you. She does this to make me think I'm no
good. I must be down. She likes me to be down, then I must
know that I'm not so good, nobody would take me....""'

-Rachel Lydia Ndabezitha

"Let's say this cushion is lying like this. She'll come and say,
'Why did you make this lie like this?' And then you start to say, 'I
never done that!' and then she starts to say, 'No, it's only a joke.'
And that pricks you. Everything that is wrong in the house, it's you.
They think the black people are the stupid ones. A mistake is a
mistake. They think because you're a black woman, you're always
wrong. Everything that is mixed up, it's you."

-Eunice Tholakele Dhladhla

"I have no feelings for [my employer] because she has none for
me.149

"I feel pity for her.. .. " 1,s

"Shame, I'm sorry for my madam. I don't want to leave my madam
because if I leave her she will do this to the other fools like me, but
the other fools will walk away.""'

-Rachel Lydia Ndabezitha

The Statistics

Many white employers treat their employees as children or possessions.
They openly distrust the workers, and yet perceive the relationship as
being mutually satisfying. The effects of this "working" relationship are
far-reaching, as Whisson and Weil explain:

[Tihe servant is invariably placed in a position inferior to that of her
employer. Her lower status is not confined to the work situation,

1' Rachel Lydia Ndabezitha, quoted in Gordon, supra note 53, at 126.
Eunice Tholakele Dhladhla, quoted in id. at 242.
Anonymous speaker, quoted in Cock, supra note 7, at 69.

150 Id.

Rachel Lydia Ndabezitha, quoted in Gordon, supra note 53, at 120.

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Columbia Journal of Gender and Law

but pervades her total identity. She does not feel inferior simply
because she is not white, she feels inferior in almost every aspect
of her being. In short, she feels herself to be and is treated by
society as an inferior person. s2

Viewing domestic workers as incompetent children in need of protection
seems to serve as a justification to white employers for placing themselves
in a position of superiority to their employees. 153

Invariably, workers either are called "girl" or addressed by a first
name, usually an English one assigned because the women's African
names are deemed too difficult to pronounce or to remember." "The
ordinary 'girl' grows up to be a lady, [but] the servant remains a 'girl' for
ever.""s Few of the employers with whom I spoke used their employees'
African names or surnames. Cock, too, found that "only 10 per cent of the
employers in [her] depth sample knew their domestic workers' full
names."'" In my own experience, whenever I spoke to employers and used
a domestic worker's full African name, I usually encountered initial
confusion, followed by something along the lines of "Oh, you mean Annie."

Similarly, many of the women with whom I worked did not know their
employers' names, for they were to be referred to only as "Madam."
Whisson and Weil explain:

The[se] forms of address commonly used in the employment
situation underline and express the distinction in status. Without
conscious humour, employers will refer to themselves as "Madams"
and will expect their employees to use the respectful term when
speaking of "My madam." The reciprocal term implies a child-like
status-"maid," "girl" or the use of the first name of the employee,
rather than the surname and title, i.e., "Annie" rather than "Mrs.
Jones.""ts

Although employers may not realize that by withholding their names
they gain the advantage of limiting their employees' recourse to small
claims court, I frequently encountered that problem.

" Whisson & Weil, supra note 65, at 38.
"Few employers can escape entirely from the moral problems of living in

a society which is based on a premise of inequality, where discrimination on the
grounds of colour pervades every aspect of life, inconveniencing the whites in
dozens of ways and insulting the non-whites in hundreds of ways." Id. at 40.

'5, Kedijang, supra note 108, at 9.
'5' Whisson & Weil, supra note 65, at 39.
'5, Cock, supra note 7, at 74.
's Whisson & Weil, supra note 65, at 36.

[Vol. 2:1



Hearing the Voices

Not knowing even an employee's name may also signal a lack of
knowledge about her in general. In Cock's study, "[olverall, employers
[did] not know as much about their servants as their length of employment
might warrant.... Only 40 per cent knew what level of schooling their
servant had and 44 per cent did not know whether or not she had children
attending school.... .,"'

Relations between white employers and their African employees also
display the strong distrust white women feel for their domestic workers.
In many cases, employers proclaim their belief that their employees are
thieves. "If anything goes missing in the house, the maid is often blamed
and wages illegally docked for the missing or broken item."'" One
employer told me that, "I've come to the conclusion you musn't be good
to them." " Another told me that, "You can not speak to Augstina; she's one
of the most unsatisfactory workers I've ever had; I gave her the job because
I felt sorry for her; times are hard. She's so stupid you can't talk to her.""1

Employers ridicule workers, joke about mistakes, and use derogatory
labels such as "kaffir."" Such treatment is "common in domestic service"'6

and pervasive.
Yet for all this mistreatment, a strong belief seems to exist among

white employers that their employees feel as if they are a part of the
family, usually in a manner in keeping with the childlike status assigned
to them. Cock explains:

Many employers [in her study] described their servant as one of the
family. This implies that she is seen in a role-specific dimension,
that her life is viewed as totally enmeshed with that of her
employers. Yet not one of the domestic workers in the sample saw
herself as one of the family and some voiced cynicism about their
employers' use of this phrase. In no case was there the sharing of
power and resources that authentic family membership might be
thought to involve.'"

Several employers with whom I spoke defended themselves by claiming
that they treated their employees as "one of the family."

" Cock, supra note 7, at 118. "Overall, only two employers of those who knew
their servants had school-going children knew the cost involved." Id.

"' Brown, supra note 83, at 2.
Telephone Interview with employer (June 25, 1991).

16 Telephone Interview with employer of Makresmise Augstina B. (Aug. 1,
1991).

11 Kedijang, supra note 108, at 18.
16 Id.

'" Cock, supra note 7, at 112.

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Columbia Journal of Gender and Law

The Threat of Violence

The Stories

- Although I heard many stories of slapping and hitting, the most
horrifying was that of Ida S., who came to us after her release
from two weeks of hospitalization, necessitated by a beating with
an iron pipe by her employer's husband and father. She had
stitches over both eyes, under her left eye, and inside her mouth,
and was missing several teeth. - 11

- [A] live-in domestic was employed by a male in Bellevue. Some
time in 1989, her employer arrived at his house and found her in
the kitchen. He touched the domestic worker in the region of her
private parts saying that her "thing" is big. The worker then took
exception to this act, got angry and walked out of the kitchen.
When the employer noticed that she was cross, he chased her out
of his premises with a firearm. He locked the domestic worker's
room and the gates.- 16

The Statistics

Domestic workers suffer particular forms of violence and harassment
in a society where Africans are already subjected to often unfathomable
brutality.67 Kedijang points out the special vulnerability of African domestic
workers:

For South Africa, violence against domestic workers is, at least in
part, rooted in social inequalities of power and rights between
individuals of different races, sexes and classes. By virtue of being
black and female, with no legal protection and no political rights,
domestic workers tend to become immediate targets of aggression
in the white household.'"

Figures on physical violence against domestic workers are difficult to
obtain for the same reasons that obtaining information about any domestic

'" Interview with Ida S. in Johannesburg (July 24, 1991).
' Kedijang, supra note 108, at 16.

For an example of violence against African farmworkers, see Lauren Segal, A
Brutal Harvest: The Roots and Legitimation of Violence on Farms in South Africa
(undated). Segal's point that farm violence is "well hidden from public
scrutiny," draws a parallel to the hidden violence against domestic workers. Id. at 4.

'" Kedijang, supra note 108, at 24.

[Vol. 2:1



Hearing the Voices

violence is problematic. "Apart from being a sensitive and personal area
to explore, many of the offenders do not admit to committing acts of
violence. Similarly, victims and onlookers such as neighbours and relatives
are reluctant to talk about their respective experiences or observations.""
Therefore, women hesitate to report violence, as the lack of first person
stories suggests, making "[it] difficult to make generalisations about
physical cruelty to domestic servants."7" None of my clients gave me
such a reason for their dismissal.

However, Kedijang does assert that "[pihysical violence against
domestic workers is presently reported to be on the increase." 7' She sees
"[tihe increasing incidence of the white 'baas' [boss] coming home to beat
up a domestic worker.., not only [as] a barometer of fear, but [also as] an
indication of the frustration generated by a feeling of loss of control in the
political and socio-economic environment." "

Sexual harassment is another form of violence against domestic workers
that is extremely difficult to locate or prevent. Kedijang finds the reasons for
underreporting this type of violence to be "numerous; the society regards
sexual harassment as a 'joke' and a victim who complains or institutes
action against the employer may be regarded with suspicion and distaste."' 3

She believes that domestic workers are especially at risk because

[Un the case of domestic service, sexual harassment is characterized
by an unwelcome imposition of sexual requirements in the context
of extreme inequality of power in the master-servant relationship,
combined with a desperation to keep the job on the part of the
worker. Domestic workers may be seen as people whom their
employers can use for anything and everything. The worker faces
a dilemma in that if she accepts the advances, she may suffer
humiliation and an impairment of her dignity. On the other hand,
if she refuses the advances of her employer ... she may be
dismissed."

"9 Id. at 2 (footnote omitted).
"" Cock, supra note 7, at 78. "The main source of difficulty is the hidden, or

masked, nature of domestic crime generally." Id.
'n Kedijang, supra note 108, at 12. "Union officials express great concern at the

growing incidence of cases, especially of physical assaults, flooding their offices.
They identify the country's current uneasy political atmosphere as one of the rea-
sons for this increase." Id.

in Id. at 3.
"3 Id. at 15.
174 Id.

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Columbia Journal of Gender and Law

African Women's Cultural and Social Status

The Stories

"African laws, you must ask the husband everything....
Everything you must ask the man and if he say no, it's no. It's
African law.'""

-Epsie Mtomkulu Zondo

"If it's Zulu custom they say a woman is a dog. Because I am a dog,
if he wants to marry another woman, he can marry another woman.
We can be five if it's Zulu custom." 76

-Rachel Lydia Ndabezitha

"When you get married, your parents tell you if you find those
people eating snakes, you must eat them. So that you go there
knowing that whatever hardship you find there, you've got to
obey them.... That's very difficult. But you adjust yourself. You
cope. You've got to cope. It's a terrible thing with us, marriage. You
are like a bought somebody, you've got to obey the orders.... But
today it's different; they don't do these things today.""r

-Margaret Mongcibelo Nhlapo

"You see, our fathers weren't as these parents today. They had to
choose everything for you. If they say, 'We want you to get married
to so and so,' you didn't have to argue. Otherwise, if you argue,
they tell you, 'Get out of the house!'""'

-Elizabeth Nomvula Tshayinca

Epsie Mtomkulu Zondo, quoted in Gordon, supra note 53, at 26.
" Rachel Lydia Ndabezitha, quoted in id. at 120.

Margaret Mongcibelo Nhlapo, quoted in id. at 222-23.
Elizabeth Nomvula Tshayinca, quoted in id. at 71.

[Vol. 2:1



Hearing the Voices

The Statistics

African women's oppression in South Africa arises from a combination
of white and African societal attitudes. Frene Ginwala explains that
African women "have to acknowledge that oppression of women in South
Africa is not only a consequence of conquest and white domination, and
make a commitment to abolish all vestiges of patriarchy in our institutions
and practices, not just those that followed conquest.""

In the South African tribal traditions "[a] woman's role is explicitly
defined in terms of looking after her husband, his family and her children.
The home is her place, though even within this, her husband is in control.
Men are assumed to be the thinkers, the decision makers in all spheres of
the society."" This power distribution between men and women is
reinforced through cultural attitudes toward women as daughters, wives,
and mothers. Thandabanto Nhlapo calls for an end to "romanticising
custom to the extent of closing our eyes to some of the horrific consequences
of a family law that does not recognise the equal humanity of women." 8 '

In the eyes of customary tribal values, women are perpetual children '$'
who remain in the care of their fathers until marriage, when they become
the property of their husbands." This view of women as property is
reflected in the custom of "lobolo," in which the husband pays money to
his new wife's family in exchange for marriage. Thus, "[tihe marriage
contract functions as a system of exchange in which women and goods

'" Frene Ginwala, Formulating National Policy Regarding the Emancipation
of Women and the Promotion of Women's Development in Our Country 3 (1989)
(unpublished manuscript, on file with CALS).

'" Transvaal Rural Action Committee, Demanding a Place Under the Kgotla
Tree: Rural Women's Access to Land and Power 7 (Jan. 1991) (unpublished
manuscript, on file with the Transvaal Rural Action Committee, Johannesburg)
[hereinafter TRACI.

.. Thandabanto Nhlapo, The Family in a Traditional and Customary Law
Context 5 (unpublished paper, on file with CALS).

" See also discussion of employers' treatment of domestic workers as children
or property, supra text accompanying notes 132-64.

"' See TRAC, supra note 180, at 5-6. Nhlapo equates this "perpetual minor-
ity" with a "lack of legal personality," which she believes may have "a direct
bearing on violence." Nhlapo, supra note 181, at 6. This minority status is codi-
fied in the Black Administration Act No. 38, § 11 3(b) (1927) ("1927 Act"). Legal
Resources Centre, Handbook for Public Interest Lawyers 183 (1991) [hereinafter
LRC]. A woman's majority at marriage or at age 21 is recognized only by § 14 of
the Natal Code of Zulu Law (Natal Code) and the KwaZulu Act on the Code of Zulu
Law (KwaZulu Code). Id.

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Columbia Journal of Gender and Law

transfer ownership. An ethos of the women as the men's property
prevails."'"

Other customs perpetuate the idea of women as property. "Soronate"
requires the younger sister of a woman unable to produce children to
become her surrogate, and "levirate" transfers the widow of a childless man
to a relative to continue the lineage."* Furthermore, a man may divorce his
wife for adultery but she may not do the same, presumably because a
man having extramarital affairs is looking for another wife.'

Laws created by whites (civil laws) further affect the status of African
women. Marriage laws severely disadvantage those African women
married either by custom or civilly before 1988 when an amendment'8 7 to
the Matrimonial Property Act of 1984 was enacted."M The 1988 Amendment
made African marriages performed under civil law after 19881s9 functionally
the same as the marriages of all other couples, but specifically excluded
those marriages of individuals living in the self-governed territories and
"independent" homelands."8

However, civil African marriages entered into before the 1988
Amendment and not changed by notarial contract"" are automatically out
of the community of property,'" so that all accumulated assets of the

I" Tracy Segel & Dana Labe, Family Violence: Wife Abuse, in People and
Violence in South Africa 251, 256 (Brian McKendrick & Wilma Hoffman eds.,
1990). Nhlapo also presents the view of wives and children as economic assets.
Nhlapo, supra note 181, at 5.

I"s See Nhlapo, supra note 181, at 6.
'' Id. at 4. See infra note 196 for codification of polygamy.

Marriage and Matrimonial Property Law Amendment Act No. 3 (1988)
("1988 Amendment").

18 Act No. 88 (1984) ("1984 Act"). The 1984 Act lifted restrictions on non-
African women's legal power within post-1984 marriages. See June Sinclair, An
Introduction to the Matrimonial Property Act of 1984, at 14-55 (1984). African mar-
riages are generally exempted from the 1984 Act. See id. at 62-68.

I" The 1988 Amendment allowed a two-year grace period during which
African couples married before 1988 could change their marital status by notarial
contract (see infra note 191), with the consent of both spouses. LRC, supra note 183,
at 187-88.

190 Id. at 186. The excluded marriages are still governed by § 22 of the 1927 Act.
Id.

191 A notarial or antenuptial contract is an agreement that may change the legal
status of a marriage, and therefore, change the automatic distribution of proper-
ty upon divorce.

1 Under community of property, all assets of both spouses are pooled. However,
either spouse may enter into a transaction controlling the joint estate without the con-
sent of the other. LRC, supra note 183, at 190. Because of the dangers of this system,
many couples contract for an accrual system, which keeps their assets separate until
divorce when the assets accrued after marriage are divided equally. Id. at 191.

[Vol. 2:1



Hearing the Voices

spouses remain separate.193 This situation creates a distinct disadvantage
to many women who, as minors, were unlikely to own property upon
entering the marriage. Upon a divorce, because the property of the parties
is never pooled, they would receive only those assets, if any, that they
accumulated independently. Furthermore, such marriages designate to the
husband the "marital power," which gives him complete control over all
property owned by either spouse." Of course, putting together the notarial
contract necessary to abolish the marital power and give the woman rights
in the accumulated assets of the marriage requires the funds and
connections to hire a lawyer, both of which are difficult tasks for most
Africans in South Africa.

In addition to marrying under civil law, Africans may marry under
customary law."' While customary unions appear to differ little from
civil marriages entered into before the 1988 Amendment, significant
differences exist in legal recognition of any union not officially registered.
A man may take as many wives as he wishes under unregistered customary
unions.'" Furthermore, because an unregistered customary union is not
recognized by law, any children born to such a marriage are deemed
illegitimate." Nor may a widow of an unregistered union claim benefits
upon the death of her husband unless she claims as a dependent, not a
spouse.'" Women married under unregistered customary law (as opposed
to civil law) do not inherit land upon their husbands' death.'"

Courts have become more liberal in their interpretation of
"certification" of customary marriages in cases involving the insurance
claims of widows of customary unions. The court's negative determination
in 1983 in Dlikilili v. Federated Insurance2 " that "[the certification
requirements] become[] impracticable if any sort of certificate will do,"21

"5 See Dolly Mokgatle, The Black Marriages Bill, 1 Afr. L. Rev. 1 (Jan. 1987).
i LRC, supra note 183, at 187. Even with the abolition of the marital power,

the husband remains "head" of the family. He controls all decisions relating to
domicile of the family and parental power over the person and property of the cou-
ple's minor children. Id. at 189-90.

I" See generally id. at 182-86. Customary unions are governed by § 22 of the
1927 Act. Id. at 182.

'"Id. at 182. This custom is codified in § 36(2) of the KwaZulu and Natal Codes.
Id.

"5 Id. at 185.
'" Id.
" See TRAC, supra note 180, at 5. Instead, the land is transferred to the

man's family, and his widow may remain only at their discretion. If she remarries,
she is expected to leave. Id. at 6.

Dlikilili v. Federated Ins., 1983 (2) S.A. 275.
2' Id. at 283.

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Columbia Journal of Gender and Law

and that "there would be little incentive to couples married decades ago
to register their union now, unless and until they are made aware of the
possible consequences of non-registration,"' was overturned the following
year in Monamodi v. Sentraboer Co-Operative Ltd.'

While efforts are being made to make African women aware of the
benefits of marrying civilly or registering customary unions, many
African men resist such contracts?2 Hence, unless an African woman can
convince her husband to register their customary marriage or, for couples
married prior to 1988, create a notarial contract, she functionally remains
a dependent of her husband.

Legislation in the areas of contraception and abortion similarly
disadvantages all women, and African women to a greater extent. While
contraception and sterilization are often encouraged for African women,
both are dangerous and often given without consent." "Contraceptives
given out by the Department of Health are often powerful and potentially
dangerous.... State clinics usually will not give out diaphragms. The
Department of Health seems to feel that women are too stupid to take
control of contraception themselves."" Ruth Mompati asserts that "[slo
blatant is the exploitation of women, that even women's fertility has been
racially categorised and subjected to state priorities: white women are
exhorted to fulfil their national duty and have 'babies for the republic,' black
women are warned that too many children means poverty."' Furthermore,
for many women "[tihe real barrier is men. Women want to take control of
their fertility, to plan their lives according to their needs. This threatens

"0' Id. at 282.
Monamodi v. Sentraboer Coop. Ltd., 1984 (4) S.A. 845. See also Mgoqi v. Protea

Assurance Co. Ltd., 1985 (4) S.A. 159, finding that "[the Legislature is presumed to
have known that outside [a] few areas .... no register of customary unions existed,
which meant that the widow's right to sue was rendered nugatory if the certificate
was required to reflect an entry in a register of customary unions." Id. at 162.

See, e.g., Motgatle, supra note 193. Black Sash and other human rights
groups are contributing to these efforts.

While "women clearly favoured a marital contract that gave them dual
power within the relationship," TRAC, supra note 180, at 11, "[mlany men resist
acquiring a marriage certificate because they feel it reduces their marital powers."
Id. at 5.

See Barrett et al., supra note 54, at 169.
Dot Cleminshaw, Women's Right to Informed Choice on Gender Issues 5

(1991) (paper presented at Black Sash National Conference 1991, on file with Black
Sash).

Barrett et al., supra note 54, at 173.
I Ruth Mompati, Putting Women on the Agenda, Speech at Lawyers for

Human Rights Conference 4 (1990) (transcript on file with CALS).

[Vol. 2:1



Hearing the Voices

men, for whom children are often symbols of their maleness and
virility."21

Despite exhortations to African women not to have children, abortion
is a crime in South Africa unless pregnancy endangers the physical or
mental health of the mother;2" presents a serious risk of irreparable and
serious handicap to the child;212 results from "unlawful carnal intercourse"; 21 3

or where the mother is mentally unable to comprehend the implications of
pregnancy. 14 In all cases, the opinion of the administering doctor must be
supplemented by written certifications of two additional medical
practitioners. 215 This proposition is an expensive one, with a particular
impact on African women, who have the least money and access to
contraceptives of all South African women.

Not surprisingly, abortions are "rarely sought through legal means. The
result is that numerous women suffer permanent injury or death due to back
street and home abortion techniques." 21 6 Approximately 300,000 women in
South Africa have illegal abortions each year.217 In the first six months of
1989, 35,038 legal operations were performed to complete illegal abortions
done elsewhere. 21 8 Overall, about ten percent of illegal abortions result in
death, and many more in sterility.219

210 Barrett et al., supra note 54, at 171.
2 1 Abortion and Sterilization Act No. 2, § 3(1)(a)-(b) (1975), as amended by Act

No. 48 of 1982.
2 Id. § 3(1)(c).
213 Id. § 3(1)(d).
214 Id. § 3(1)(e).
210 Id. § 3(0)(a)-(e). Not surprisingly, the Act was created by an all-male com-

mittee with a strong influence of religious fundamentalism. Cleminshaw, supra note
207, at 7. The Civil Rights League's submission to the Director-General of National
Health recommends allowing a woman to make an informed and counseled deci-
sion to abort within the first 12 weeks of her pregnancy. Id. at 9. But see S v. Collop,
1981 (1) S.A. 150, finding:

Parliament would, I apprehend, be surprised to learn that, in its wisdom,
it had placed on the statute book a law which made legal an abortion pro-
cured by any unqualified person or quack carrying on business in a back-
street provided only that the operation was performed on the patient
before the end of the second month of pregnancy.

Id. at 163.
216 LRC, supra note 183, at 194.
2 7 Id. at 194 n.76.
211 Cleminshaw, supra note 207, at 7.
219 Barrett et al., supra note 54, at 174.

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Columbia Journal of Gender and Law

DOMESTIC WORKERS' AGENDAS FOR CHANGE

Remembering to Listen

Understanding the lives domestic workers live is only one step in
bringing their voices into legal discourse. Feeling some of the common
pains that arise from being a woman, being a Black woman, or being a
working-class woman may tempt a reader to express her indignation
immediately. Her own struggle for power and voice may seem to her to
justify using any megaphones possible for expressing how these women live
and how change can occur.

But in such a scenario the crucial second step remains untaken. It is not
enough to hear these women talk of their circumstances. To end their'
stories here would still lead to the appropriation of their pain by other
women with stronger political voices. To avoid this phenomenon, feminists
must listen further as domestic workers relate their own agendas for
change.

Why Not Just Demand It

The Opinions

"If you complain, you can lose your job. She'll tell you about all the
other people who come to the door looking for work. "

2"

-Eldah Mthuludi

"You can't complain or you might lose your job. If you complain
your employer tells you about all the girls coming to the door
looking for work."22' 1

"I am afraid she will sack me if I speak again."m

The Options

Demanding better conditions is difficult because of high unemploy-
ment,m leading many women to take jobs despite unacceptable conditions.

220 Eldah Mthuludi, quoted in id. at 32.
221 Anonymous speaker, quoted in Cock, supra note 7, at 19.
Id. at 22.

m Some South African economists "estimate that there are about three million
blacks without work-20 to 25 percent of the workforce of the whole of South
Africa." Ravenhill, supra note 120, at 5.

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Hearing the Voices

Black Sash attempts change through employer education, 4 but ultimately
can only refer clients to SADWU and rely on small claims courts to provide
redress for wrongful dismissals.

Constantly aware of their tenuous job status, domestic workers must
seek other means of bettering their circumstances and the circumstances of
women in the future.

Education

The Opinions

"[My employer] does not care. She does not like our children to go
to school because she says they end up nowhere." '

"They say it's useless to educate a daughter. She going to be
married and she won't work anything for you, won't bring any
money."'

-Miriam Ngulube

"My feeling when I think my child mustn't go to school! I was
getting mad! All my daughters, they from high school. Four of
them! Ooh, I was fighting for my daughters! Ja, I used to have a
petticoat you see, a mealie-meal bag. Ja! And even for my pantie.
I cut that mealie-meal bag and make a pantie. Push my four
daughters to school.... I don't want them to suffer." 7

-Epsie Mtomkulu Zondo

The Options

With the demise of apartheid laws, inferior education remains the
most obvious way in which the government continues to perpetuate

n See Penelope Geerdts, Masisebenzisane: Let Us Work Together (1991),
which is published and distributed by Black Sash, and lists suggested wages,
hours, overtime, vacation, accommodations, meals, transportation, clothing, and
use of facilities. The booklet also recommends drawing up a written agreement
upon hiring and sets out the terms of dismissal. Id.

Anonymous speaker, quoted in Cock, supra note 7, at 29.
Miriam Ngulube, quoted in Gordon, supra note 53, at 162.
Epsie Mtomkulu Zondo, quoted in id. at 32.

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racially motivated class distinctions. Much of domestic workers' limited
job mobility stems from their lack of training for other, higher-paying
jobs.' In Cock's study, "[tihe great majority of domestic workers ... had
only a minimum amount of formal education. [Sixty-three] per cent had
been to school but the vast majority, three-quarters, had not progressed
beyond Standard V [fifth grade]. No one in the sample had progressed
higher than Standard VIII [eighth grade]."2"

Despite domestic workers' great hopes for better educational
opportunities for their children, 23 schools in South Africa remain
segregated, with no anti-discrimination laws in place to repair the effects
of apartheid. The African schools suffer from overcrowding, insufficient
resources, and difficult physical learning environments. "In some township
schools, there are 100 pupils to every teacher"2 and "[giross overcrowding"
was "highlighted" during a National Education Co-ordinating Committee
tour in July, 1991.1 Some African schools have no money to provide even
textbooks-the teachers must "beg... or borrow" them.2 "Broken window
panes, missing doors, no toilets or water" are a "common feature" of
African schools.' For example, the school established by residents at
Weiler's Farm, a shack settlement, is a "cardboard and zinc structure
supported by wooden pillars. Inside, the older children... work diligently
on donated stationery at rapidly disintegrating desks. At least 50 younger
charges carry their chairs outside and then shiver under the early morning
winter sky, waiting for their lesson to begin." 5

' Cock points to lack of educational opportunities as one of the factors
which "trap" domestic workers. Cock, supra note 7, at 4.

Id. at 17.
"Their hopes for the future focused on their children, and education was seen

as the means whereby their children could escape to a better life." Id. at 18.
"' Portia Maurice, Go Back to School, Piet Clase, Weekly Mail, June 14-20,1991,

at 1.
Phil Molefe, Squalor, Overcrowding at Black Schools a Shock for Diplomats,

Johannesburg Star ("J'burg Star"), June 18,1991, at 3. [hereinafter Molefe, Squalor].
_ Portia Maurice, The Kids Who Learn in Cardboard Classrooms, Weekly

Mail, June 14-20, 1991, at 11. [hereinafter Maurice, The Kids].
Molefe, Squalor, supra note 232, at 3.
Maurice, The Kids, supra note 233, at 3. "[T]aking the increasing cost of

education into account, the real increase [in the education budget] was only 6
percent [from 1987 to 1990]. Against that the increased enrol[1]ment of pupils
requires a 14 percent annual increase in the education budget merely to keep pace."
Patrick Laurence, A Boat with Too Many Holes, J'burg Star, June 15,1991, at 15. In
light of inadequate government policies, some African groups have begun a
campaign to take over white schools closed for lack of enrollment. The government
has responded by forcing them out and often selling the schools to private

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Hearing the Voices

Despite the picture presented by such overcrowding, the dropout rate
is extremely high. It has been reported that of every one hundred African
pupils who enroll in first grade, only sixteen make it to tenth grade.'
For example, currently, only nine thousand out of seventy thousand
children of school-going age in Alexandria, an African township near
Johannesburg, attend school.2

Without decent education, African women remain confined to unskilled
manual work, and domestic work provides the most accessible market.
They therefore hope to provide their children with a better education than
their own, and many save money for the best schools possible. The belief,
"This is the last generation of domestic workers," is voiced often and
proudly.

Creating Change for Themselves

The History

"We were not afraid [during the pass law protest march on the
Union Buildings in Pretoria], I don't know why we weren't. People
die sometimes that way you know, not caring whether they die or
not .... [Wie came home singing Nkosi Sikelela and Morena Buluke
and standing for a few minutes in silence. It felt great, really!"'

-Thokozile Virginia Mngoma

"[The 1958 Alexandria protest had been scheduled to start at eight
o'clock.] [Alt about half past eight the women didn't come, they
simply poured in from all comers of the square. They were running,
pulling their jerseys behind them, many carrying babies .... You
know, I've never seen such a thing! Within a few minutes the
whole square was full!"'

-Thokozile Virginia Mngoma

educators rather than turning them over to the African students. See, e.g., Phil
Molefe, FW Told to Act on Black Schools Now, J'burg Star, June 21, 1991, at 6; Phil
Molefe, Govt Threat over Plan to Occupy School, J'burg Star, June 26, 1991, at 9;
Phil Molefe, Lots of Space but Blacks Turned Away, J'burg Star, June 3, 1991, at 2;
Phil Molefe, Occupation of School Stopped, J'burg Star, June 26, 1991, at 1.

Laurence, supra note 235, at 15.
237Molefe, Squalor, supra note 232, at 3.

Thokozile Virginia Mngoma, quoted in Gordon, supra note 53, at 100.
Id. at 101. In the end, the organizers of the Alexandria protests decided to

carry the passes that restricted their movement outside of their designated "home-
lands." Id. at 103. Ms. Mngoma recounts: "I was strongly against it. It made me

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Columbia Journal of Gender and Law

"I didn't realise it at first, it was only afterwards, as I grew up, that
I realised that kitchen work was no good for a person like myself.
I could see the political implications. I already knew that we were
being exploited by the whites in the kitchens. When I thought of
the work I did, and getting nothing for it, it broke my heart. It really
made me angry."4

-Thokozile Virginia Mngoma

"[The South African Domestic Workers Association (SADWA),
which later became SADWU, broke from the Domestic Workers
Education Project (DWEP) and other training groups run by white
women because, the white women] were trying to protect those
ladies there. Maybe those ladies don't want to be protected. They
don't ask the ladies, 'Do you want to be protected?' Martha
Fordyce told me, 'You know, Margaret, we've got to protect them
from politics.' She didn't ask those people if they wanted to be
protected. I mean, you've got to let go sometimes. They don't want
to let go. So it's a one-sided thing and I hate it. I'd rather starve than
have somebody telling me what to do with my life. Some of these
white women don't like SADWA because that is the thing that
will bring light to black women's eyes."241

-Margaret Nombgcibelo Nhlapo

"When I was given this telephone [at the newly independent
SADWA office] I was so thrilled. This, to me, was a step ahead. I
started communicating with the other SADWA members and
SADWA in Durban and Cape Town. After a month Norah Kau
came and joined me. We bought that small table. We started
addressing envelopes, arranging a meeting."2 42

-Margaret Nombgcibelo Nhlapo

feel sick, really it was very bad, but I simply had to. It's a pity. We should start all
over again. We could do it again." Id.

For a history of African women's resistance to carrying passes, see Cheryl L.
Poinsette, Black Women Under Apartheid: An Introduction, 8 Harv. Women's
L.J. 93, 111-14 (1985).

210 Thokozile Virginia Mngoma, quoted in Gordon, supra note 53, at 98.
241 Margaret Nombgcibelo Nhlapo, quoted in id. at 228.
242 Id. at 229.

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Hearing the Voices

"I just see SADWA's future being work and work for domestics and
all the domestic workers joining SADWA and we all working
together." 3

-Margaret Nombgcibelo Nhlapo

"Why do you want to build SADWA if it is not yourselves? Because
me, being Caroline, I'm not SADWA. SADWA should mean all
domestics working together to change their lives."2"

-Caroline Ramokone Sotloe

"SADWA must have its own office, run by domestic workers. If we
have someone who never been domestic workers before, it's those
who's going to give us headaches." '

-Violet Gatote Motlhasedi

"We must teach the people how strong you can be when you are a
domestic worker. Not to let the employers just push you." 2"

-Violet Gatote Motlhasedi

"I'll be sad to leave domestic work because of SADWA. I can
really die about SADWA." 247

-Elizabeth Nomkhitha Siphika

A Union of Domestic Workers

"You have strength. You can clean and cook. She [your employer]
can't."2'

-Eunice Tholakele Dhladhla

243 Id. at 230.
1" Caroline Ramokone Sotloe, quoted in id. at 203.
', Violet Gatote Motlhasedi, quoted in id. at 262.

246 Id.
247 Elizabeth Nomkhitha Siphika, quoted in id. at 252.
241 Eunice Tholakele Dhladhla, Address at SADWU training session in

Johannesburg (July 18, 1991).

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"No one must call you a girl. You're not a girl anymore. Comrades,
let's fight for that."*4 9

-Eunice Tholakele Dhladhla

"If she says, 'Eunice,' say, 'Yes, Irene.' If she says, 'Mrs. Dhladhla,'
say, 'Yes, Mrs. Smith. '"'

-Eunice Tholakele Dhladhla

SADWU Demands

SKILLED FULL TIME WORKER
R450.00 [about $167] per month for an 8 hour day for 5 days per
week, plus full meals and protective clothing to be provided.

MATERNITY LEAVE
Maternity benefits should be given to all domestic workers 8 weeks
prior to giving birth and 6 weeks after giving birth. Days off to
attend anti-Natal Clinics, wages not to be deducted.

ANNUAL LEAVE
The worker shall be entitled to 21 working days paid leave after
completing 12 months of service .... Leave pay shall be paid
before the worker goes on leave. Workers are entitled to all Public
Holidays.

WE DEMAND A LEGISLATION THAT COVERS:
1. WAGE DETERMINATION ACT
2. WORKMANS COMPENSATION ACT
3. U.I.F. [unemployment insurance] ACT

MEDICAL AID
Sick leave[:I The worker shall be entitled to 14 days of paid sick
leave in any year ....

249 Id.

Id.

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Hearing the Voices

BENEFITS
The employer shall provide the following[I:]

Accommodation

Meals
Transport allowance (bus or trainfares)

Pension
Medical Aid
Annual bonus-one month
Assistance with housing education

PENSION
Pension to be provided for the worker by the employer.

CONTRACT

It is very important to have a written and signed agreement of
employment after negotiations ....

THE RIGHTS OF THE WORKER
ALL WORKERS SHOULD BE PROTECTED BY THE LABOUR
RELATIONS ACT. IT IS NOT A PRIVILEGE BUT A RIGHT.51

"We'd like to see domestic workers recognized by the Manpower
[Commission] and we'd like to see domestic workers earn the
living wage.... "22

-Eunice Tholakele Dhladhla

The Options

Unionizing is difficult for domestic workers because of the number of
employers and the low ratio of employees to employers. Furthermore, so

251 SADWU, Demands for Legislation 1-2 (1989). See also Resolutions Adopted
at the General Conference (Nov. 1986), reprinted in Cock, supra note 7, at 177-80.
The Resolutions include demands on working conditions, discrimination, living con-
ditions, and education, as well as affiliation with the Congress of South African
Trade Unions and a role in anti-apartheid activity. Id.

I Interview with Eunice Tholakele Dhladhla, SAD WU, in Johannesburg (June
24, 1991).

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many women are looking for domestic work that most are afraid to demand
higher wages and better working conditions for fear that it will cost them their

jobs. Eunice Dhladhla of SADWU explained to me, "Domestic workers
don't want to join unions because they are afraid once employers find out

they are a member they will be dismissed."2- Moreover, "Because members
work in isolation and there are few available venues for meetings, it is

difficult for them to organize.... [E]ven in the unlikely event of domestic

workers gaining legislative recognition and protection, the nature of their
employment would make monitoring by a union extremely difficult."'

Despite these concerns, membership in SADWU is growing. Although
the 14,963 members of the Johannesburg branch account for only about one
quarter of the domestic workers in the area,' their membership continues
to rise. The meeting I attended, which included one woman's story of her

successful demand for significantly higher wages, filled the room with hope.
SADWU is run by domestic workers, and within its walls they can raise
their voices and be heard. In the very assertion and reassurance of such
power, they are improving their conditions.

A Note on Other Voices

Of course, not only domestic workers are coming together to change
their conditions. To avoid presenting such an unbalanced picture, this

section presents a brief overview of the louder voices African women are
gaining in the changing political front. The major women's organization
in South Africa is the African National Congress Women's League

(ANCWL).' "The League now bears the hopes of women who have

struggled for many years, in the face of enormous state repression and at
the cost of managing the triple shift-family, work and political activity-
to organise women against patriarchy and apartheid."' The ANCWL's
agenda, which focuses on increasing political representation for women'

2 Id.
23 Gordon, supra note 53, at xxvi.

Interview with Eunice Tholakele Dhladhla, SADWU, in Johannesburg (June
24, 1991).

m Shireen Hassim, From Handmaiden to Comrade: The ANCWL and the
Question of Political Power 1 (1990) (unpublished manuscript, on file with CALS).

231 Id.
See, e.g., the ANCWL's demand that there be a 30% quota of women on the

ANC's National Executive Committee and the eventual compromise. Mark
Gevisser & Phillip Van Niekirk, Compromise over Quota of Women, Weekly Mail,
July 12-18, 1991, at 1; Mark Gevisser, The ANC and the Mediocracy, Weekly Mail,
July 12-18, 1991, at 14.

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Hearing the Voices

and on constitutional guarantees of equal rights for women,5 is very
different from that expressed by domestic workers in these studies or the
women with whom I have talked. Most domestic workers would find it
difficult to make time for the ANCWL meetings or to pay dues.

Yet despite their differing agendas, these women may benefit from each
other, especially if communication between them is improved. Shireen
Hassim asserts that:

[t]here is... a two-fold task which confronts us. The first task is
how to ensure greater representation of women on decision-making
bodies in the crucial short-term, when many policies and legislation
are being formulated. The second task relates to the longer-term:
how to create a base from which women can ensure that their
demands are met by the state .... ".

This reminds one that the legal constraints on domestic workers' marital
power and reproductive freedom, which they cannot change themselves
until they achieve greater political power, are not being ignored.

The solidarity among domestic workers coupled with cooperation
with those women who share common circumstances illustrates a hopeful
possibility for working together as women without allowing individual
experiences to be appropriated by a vocal majority. While the circumstances
of women other than domestic workers are as different as their voices, they
do share with domestic workers some common experiences across which
connections may be forged so that domestic workers may retain control over
their own agenda but will not remain fragmented from the other African
women of their country.

CONCLUSION

Only when we confront the realities of sex, race, and class, the ways
they divide us, make us different, stand us in opposition-and
work to reconcile and resolve these issues-will we be able to
participate in the making of feminist revolution, in the
transformation of the world."6

See, e.g., Brigitte Mabandla, Protecting Women's Rights and Promoting
Gender Equality in a Democratic Non-Racial, Non-Sexist South Africa (1990)
(paper presented at Lawyers for Human Rights International Conference, on file
with author).

Hassim, supra note 256, at 2.
1 hooks, supra note 18, at 191.

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Admittedly, the methodology of this paper is at times awkward, the
academic debate on feminist theory bumping up against the straightforward
voices of domestic workers. Furthermore, while the written debate is rich
and full of sources, first-person stories are more difficult to come by, and
in their very scarcity one fears that they are no more representative of the
lived experiences of a group of women than are the intellectual arguments
among academics.

If nothing else, the difficulties in my research reveal the obvious truth
that legal research is not geared toward this kind of analysis. With little
focus on, indeed, an aversion to, examining life experiences and allowing
people to speak for themselves, legal methodology has yielded too few
documented oral histories and too limited means of obtaining the stories.
The chasm between the academicians and the domestic workers themselves
seems to me to indicate just how little input the domestic workers have had
into the debates, research, and analysis about themselves. The scarce
resources available validate this suspicion.

The sources, however, do help to provide the necessary initial step
toward communication. Anyone who has been the subject of open and
unwarranted hatred and distrust can begin to understand the daily hurt of
a domestic worker. The reader who has tried to decide whether to report
a case of sexual harassment feels the fear and humiliation of such a position.
Any parent who has had to endure a separation from a child, any lover who
has been forced to live apart from a loved one, experiences again through
the women's voices a measure of the anguish of their solitary lives. I
encourage the reader to return again to the voices presented, as I remember
the voices and faces of the clients who came to see me, and to try to forge
connections, to challenge her belief that she understands what they are
saying, and to move toward a greater understanding. Even after the
process of researching and writing this piece, I find that each time I return
to the stories I am brought yet closer to the women who tell them.

Through such an establishment of communication across differences
between women, the solidarity crucial to successful feminist change
becomes possible. In the very articulation, confrontation, and celebration
of difference, a bond is established. And in the sharing of similar
experiences among different women, a web of relationship is woven which
allows women to speak to each other and to society with a multiplicity of
voices sharing a common understanding.

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