<P> Forbes remarks upon a process of "lumping", whereby characteristics other than skin color, such as hair color or curliness, act as "triggers" for color categories "even when it may not be appropriate ." </P> <P> In 1950s (and later) South Africa the "brown people" were the Coloureds, referring to those born of multiracial sexual unions out of wedlock . They were distinct from the Reheboth Basters inhabiting Namibia, who were primarily of Khoisan and European parentage . The Afrikaans terms, which incorporate many subtleties of heritage, political agenda, and identity, are "bruin" ("brown"), "bruines" ("browns"), and "bruinmense" ("brown people"). Some South Africans prefer the appellation "bruinmense" to "Colored". </P> <P> The South African pencil test was one example of a characteristic other than skin color being used as a determiner . The pencil test, which distinguished either "black" from "Colored" or "Colored" from "white", relied upon curliness and strength of hair (i.e. whether it was capable of retaining a pencil under its own strength) rather than upon any color factor at all . The pencil test could "trump skin color". </P> <P> Steve Biko, in his trial in 1976, rejected the appellation "brown people" when it was put to him incorrectly by Judge Boshoff: </P>

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