UNTERHALTER AJ responds that, to the extent that there may be any doubt as to what is meant by “accessible format copy” and “person with a disability”, regard may be had to the relevant definitions in the Marrakesh Treaty. Additionally, Blind SA says that regard may be had to the treatment of unfair discrimination on the basis of disability in various decisions of our courts as also how disability is defined in other statutes. [27] Alternatively, Blind SA submits that this Court could, using its powers in terms of section 172(1)(b) of the Constitution, make a just and equitable order that the two phrases, when used in section 19D, bear particular meanings, either as defined in the CAB, or in the Marrakesh Treaty. Or in its order, this Court could also read-in the new proposed statutory definitions of “accessible format copy” and “person with a disability”. [28] Blind SA contends that section 19D is not controversial, that the reading-in remedy is effective and operable and that the proposed remedy is not at odds with the Marrakesh Treaty and other international instruments. Blind SA says that the proposed reading-in remedy would be effective and operable, because multiple state parties to the Marrakesh Treaty do not define the scope of works to which accessible format shifting applies within their individual domestic copyright statutes. Therefore, section 19D is not an outlier. Furthermore, even in the absence of the definitions of “accessible format copy”, “persons with disabilities” and “a person who serves persons with disabilities”, the remedy is not vague because section 233 of the Constitution requires that, where reasonably possible, legislation must be interpreted in a manner consistent with binding international law. First respondent’s submissions [29] The Minister does not oppose the confirmation of the declaration of invalidity. The Minister only makes submissions in favour of the suspension of the declaration of invalidity to assist this Court to determine the appropriate remedy. The Minister submitted that while it is true that no particular concern has been raised regarding the constitutionality of section 19D, concerns have been raised as to whether the section 15