There have been a number of independently documented cases where the constitutionally protected right to protest has not been honoured by the state. One particularly well documented instance occurred in Durban in 2006 and another in Cape Town in 2012. It has also been claimed that the right to protest has been summarily denied to shack dwellers on the East Rand. It has been argued that not just ANC controlled municipalities, but also opposition Democratic Alliance (DA) ones, engage in unlawful bans on the right to protest. It has also been suggested that recent judicial interventions amount to a "de facto" curtailment of the right to protest. It has been argued that there was an increase in the unlawful banning of protests after the 2012 Marikana massacre and that this has taken the form of a "de facto" "state of emergency".