In Van Eeden v. Minister of Safety and Security , an important case in the South African of law of delict as well as the country's criminal law, the appellant, Ghia Van Eeden, was assaulted, raped, and robbed by a known, dangerous criminal who had escaped from police custody. The court held that the state was obliged to protect individuals by taking active steps to prevent violations of the constitutional right to freedom and security of the person, inter alia by protecting everyone from violent crime. It was also obliged under international law to protect women specifically from violent crime.