Corporal punishment—usually referring to adults hitting children—was abolished in South Africa in 1997. The Constitutional Court had already ruled it incompatible with the bill of rights in 1995. In that judgment, the chief justice said that in his view, "juvenile whipping is cruel, it is inhuman and it is degrading"—as well as "unnecessary." The South African Schools Act of 1996 also outlawed it. Anecdotal evidence suggests, however, that this practice is still common in many schools and homes. Educational psychologist Simangele Mayisela researched the subject for her 2017 doctorate, asking why some teachers and parents (and even children) believed it was an effective and harmless form of discipline.