Adv Ngcukaitobi advised that Parliament must think creatively when addressing land reform and think beyond compensation. He expressed the view that, in fact, there was no need to amend section 25. Parliament itself has failed to implement the redistribution provisions within section 25 through the enactment of national legislation. He further warned that any amendment of section 25 that includes expropriation without compensation may lead to further dispossession of land from indigent people.