Abstract
This study examined the whistleblower protection frameworks in South Africa and the
United Kingdom (UK), focusing on the legal, social, and institutional factors influencing
their effectiveness. The research aimed to analyse the strengths and weaknesses of
each system, identifying key barriers and opportunities for improvement. A
comparative approach was used, involving a review of legislative frameworks like
South Africa’s Protected Disclosures Act (PDA) and the UK’s Public Interest Disclosure
Act (PIDA) and an exploration of relevant case studies. A qualitative analysis of these
cases, including instances of whistleblower retaliation and institutional responses,
illustrated the practical challenges whistleblowers faced in both contexts. The study
found that while the UK framework offered clearer protections and better institutional
support, South Africa’s approach remained limited by weak enforcement, lack of
independent oversight, and societal stigmas against whistleblowers. Major findings
highlighted that South African whistleblowers often encountered significant risks,
including retaliation and, at times, violence, while public perception remained largely
negative. Additionally, the existing legal framework in South Africa did not adequately
shield whistleblowers in high-stakes or politically sensitive cases. The conclusion
drawn from the study suggested that a comprehensive reform of the PDA was
necessary, focusing on strengthening enforcement, expanding protections, and
addressing cultural barriers that hindered whistleblowing. A primary recommendation
was establishing an independent, sector-specific regulatory body to oversee
disclosures, provide support, and ensure whistleblowers were protected from
retaliation. This reform would create a safer and more transparent environment for
reporting misconduct.