[T]he US Supreme Court struck a blow against accountability for human rights violations by severely curtailing the range of possible claims in terms of the Alien Tort Statute…The court concluded that for a claim under the statute to succeed, victims must show that their claims "touch and concern the territory of the US…with sufficient force"…What is clear is that the chances of success in actions claiming compensation for violations outside the US have been significantly weakened. This leaves a gaping hole in the quest globally to hold corporations and individuals accountable for the rights violations they cause…[T]he recent decision indicates the need for governments across the globe to develop new laws allowing action to be taken against home corporations (and individuals) that become complicit in human rights violations abroad…The time is ripe for South Africa to develop a legal framework for holding its companies accountable for human rights violations committed abroad…[Refers to Shell]