In 2011 the North and South Gauteng High Courts were approached to confirm surrogate motherhood agreements in accordance with the provisions of chapter 19 of the Children's Act 38 of 2005. The judgments were reported as In Re-Confirmation of Three Surrogate motherhood Agreements 2011 (6) SA22 (GSJ) and Ex parte 14FI2011 (6) SA514 (GNP). This note concerns the latter judgment.