1. IntroductionThe Constitution of the Republic of South Africa contains a Bill of Rights which clearly states that “Everyone has the right to liberty and security of person, which includes the right to be free from all forms of violence whether private or public in origin”. This constitutional right clearly illustrates the creation of a positive legal duty for the police to protect all citizens from violence in any form. This legal duty to act positively falls to the police because they are seen as agents of the State in enforcing the protection of the rights of all human beings. They also have the constitutional duty to protect because “the purposes of the police service are to prevent, combat and investigate crime, maintain public order, protect and protect the inhabitants of the Republic and their property, and enforce and enforce the law ”. “In South African criminal law the State's responsibility to protect citizens under its government can be classified under the element of criminal conduct where a decision must be made whether or not there is liability for an omission. The big question is whether there is a mandatory legal norm that requires the state to protect all citizens under its government. The case “Minister van Polisie v Ewels” was the pioneering case concerning the state's legal duty to act positively because it was the first case to recognize it. In the “Ewels” case it was found that there is no legal obligation to prevent someone from causing harm because there is a special duty of protection only if there is: “(1) direct contact or continuous contact between the victim and the government agency or official; and (2) a justified reliance on the part of the victim." However, there are some...paper issues...that will befall them. These implications can be divided into civil law implications and criminal law implications. The civil law implications would be, for example, claims for damages. Criminal law cases, on the other hand, would lead to prosecution, imprisonment, among other things. Works Cited Carmichelle v Minister for Safety and Security and Another 2000 (4) All SA 537 (A). Act 108 of the Constitution of the Republic of South Africa 1996 .Criminal Procedures Act 51 of 1977. Govender and others v S 2004 (2) All SA 259 (SCA). Miller v. District of Columbia, 841 A. 2d. 1244 – DC: Court of Appeal 2004.Minister of Law and Order v Kadir 1995 (1) SA 303 (A).Minister van Polisie v Ewels 1975 (3) SA 590 (A).Nkumbi v Minister of Law and Order 1991 ( 3) All SA 314 (E).Van Eeden (formerly Nadel) v Minister for Safety and Security 2002 (4) All SA 346 (SCA).