MOGOENG CJ need to challenge the constitutional validity of aspects of PAIA in the public interest22 based on, among others, section 32 of the Constitution. [19] Section 32 provides: “(1) Everyone has the right of access to— (a) any information held by the state; and (b) any information that is held by another person and that is required for the exercise or protection of any rights. (2) National legislation must be enacted to give effect to this right, and may provide for reasonable measures to alleviate the administrative and financial burden on the state.” [20] The word “everyone” is wide enough to accommodate both a juristic and a natural person. Similarly, “another person” in this context suggests a person other than the State and is on the face of it wide enough to apply to a natural and juristic person, including a political party or an independent candidate. [21] The word “held” is broad. It connotes control over information captured or “held” in written form, in human memory, in some electronic or audio-visual contraption or any other form capable of holding information. The noun “record” in PAIA is thus meant to connote nothing more than a mechanism or consequence or product of capturing or keeping whatever information might be needed or required.23 This meaning is wide enough to apply to “held” in any portion of section 32. 22 Section 38 of the Constitution states: “Anyone listed in this section has the right to approach a competent court, alleging that a right in the Bill of Rights has been infringed or threatened, and the court may grant appropriate relief, including a declaration of rights. The persons who may approach a court are— … (d) 23 anyone acting in the public interest”. No wonder section 1 of PAIA says— “‘record’ of or in relation to, a public or private body, means any recorded information— (a) regardless of form or medium; 9