UNTERHALTER AJ the Minister’s power to prescribe general exceptions only applies to reproducing works. Section 13 may not be used to authorise acts beyond this. [19] Blind SA argues that this Court has drawn a clear distinction between the lawful delegation of authority to make subordinate legislation and the assignment of plenary legislative power to the Executive. Therefore, section 13 should be interpreted narrowly to avoid the unlawful assignment of plenary legislative power. [20] Additionally, Blind SA submits that leaving the realisation of the rights of a marginalised group of people to the whims of the Minister, in circumstances where he and his predecessors have failed to act for over two decades, is an affront to the dignity of persons with visual and print disabilities. Therefore, so Blind SA submits, sections 13 and 39(a) of the Copyright Act do not provide a statutory basis to afford access by print-disabled persons to accessible format copies. [21] If this Court finds that section 13 is indeed capable of a broad, constitutionally-compliant interpretation, then section 13 is limited by its wording, which only applies to reproductions. [22] Blind SA submits that although an accessible format copy of a work requires reproduction, mere reproduction does not cover activities such as distribution and transmission to the requesting entity. Accordingly, even if reproduction under the Copyright Act were interpreted broadly, it would still fail to comply with Article 4(1)(a) of the Marrakesh Treaty which states that— “[c]ontracting parties shall provide in their national copyright laws for a limitation or exception to the right of reproduction, the right of distribution, and the right of making available to the public as provided by the WIPO Copyright Treaty (WCT), to facilitate the availability of works in accessible format copies for beneficiary persons.” (Emphasis added.) 13