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BEFORE THE JUDICIAL COMMISSION OF INQUIRY INTO ALLEGATIONS OF STATE CAPTURE, CORRUPTION AND FRAUD IN THE PUBLIC SECTOR INCLUDING ORGANS OF STATE SUPPORTING AFFIDAVIT |. the undersigned, NAVARANJENI MUNUSAMY state under oath that: 4. | am a major female journalist currently employed by Tiso Blackstar Group as Associate Editor: Analysis al 16 Empire Road, Parktown Johannesburg. | have ‘boon employed by Tiso Blackstar since July 2017, Prior to that, | was employed by Daily Maverick as an associate Editor ftom April 2012. 2. The facts contained inthis affidavit are within my personal knowledge, unless it ‘appears otherwise from the context. They are, to the best of my knowledge and betef, both true and correct 3, Where | make any legal submissions, | do so on the advice of my legal representatives. PURPOSE OF THIS APPLICATION 4, This s an application in torms of Rule 3.36 read with Rule 3.9 of the Rules of the Judicial Commission of Inquiry into Alogations of State Capture, Corruption and Fraud in the Publie Sector including Organs of State (‘the Commission’) for ae on leave to: 4.1. give written and oral evidence tothe Commission; and 4.2, cross-examine Mr Kobus Roslo'se ("Mr Roelofse"), folowing my receipt of 2 Rule 33 notice from the Commission on 6 September 2019 ("the Commission's notice") and Mr Roclofse's testimony before the Commission on 18 September 2019 and 19 Soptember 2019, ‘As willbe demonstrated below, it would be necessary and in the best interests of the work of the Commission for this application to be granted. | need to emphasise at the outset end state this unequivocal: Mr Roelofse suggests in his evidence that | have been paid by Crime Inteligence, that | am cffectvaly an agent of thes or on their payroll. 1am horified by the allegation. Its fale. As appears more fuly below, the payment referred ton Mr Rocltse's ‘evidence - made 11 years ago end incktentally when | was nota journalist «is ‘entirely innocuous. MR ROELOFSE'S ALLEGATIONS CONCERNING ME 7. (On Friday 6 September 2019, | received an email containing the Commission's notice, together with an extract from Mr Rooofses affidavt | only read the email con Monday 9 Septomber 2079, thinking that the email was one of many I get from the Commission in my capacity as a journalist reporting on the Commission's proceedings, The Commission's notice claims that Mr Rocofse has implicated me “in, inter ala, allegenly participating in acts of corruption, bribery, fraud andlor money laundering.” copy of the Commission's notice and the accompanying extract of Mr Roolofse's affidavit Is attached markod annex An sora 4 8 In paragraph 140.2 of hs affidavit Roelose allges that on 9 May 2008, over 11 years ago, an amount of R143 621.78 was paid fo a Wesbank Vehicle Finance account in setement of a vehicle registered in my name and thal the amount reflected as received on the same day. He futhor alleges thatthe amount was bited against the Atlantis Motors BARUT account on 20 July 2008. During the second day of is testimony before the Commission, on 18 Seplember 2019, Mr Rocltse repeated those allegations against me, The transcript of the second day of Mr Roelefs's testimony published by the Commission is stached in elevant pat, as annex *NM2" (he relevant potions of the transcript have been highlighted for convenience). In relation to me, Mr Roelofse during his testimony stated, intr alia, the following 9.1. “The second instance that we - that we were able fo uncover was an amount of R143 621,78. It was paid to it was paid from the Atlantis ‘Motors business account fo WesBank Vehicle Finance Account in the settiement agreement of a vehicle registered in the name of Ms Ranjeni Munusamy and as far as | know she is @ joumelist. This amount reflected as received - reflected as received on the same date in the WesBank - WesBank Vehicle Finance Account held jn the name of Ranjeni Munusamy. and 9.2. This amount was debited - debited against Atlantis Motors BARUT account on 30.July 2008. In other words what had happened here ‘according to Mr Venter is he was requested fo pay over an emount of ‘money into this WesBank Vehicle Finance Access Account or account and at a later stage he then debited the (BARUT] account against this - ‘against the company account fo sotts the ammount which has been pei So effectively what it maans is that the amount was covered by the {IBARUTI account which Is funded through the sale of vehicles 10 the ‘SSA -10 Crime fntoligenco.” MP 4 40. During his third day of testimony before the Commission, on 19 September 2019, Mr Rootofse alleged that 104 102. 103. 104, “in 2014 {dic in fact contact Ms Ranjoni Munusamy and - and informed her of what Ihave found and asked her for a version and explanation. | ‘spoke about three times I think fo her. Sho then said she will speak to hor legal representative. | have never received any communication from her after that in respect of any explanation as to what happened ‘At this point in time ll can state is that the account held by Nissan - Nissan Atlantis or Atlantis Motors paid an amount into an account held by Naveranjeni Munusamy at Wesbank relating to the vehicle that she ‘owned or that person onned *So at the time when | interviewed Mr Venter he — he showed me the — the transaction. He explained to me what happened. He then indicated to-me that the amount came from Atlentis Motors on the 6 May ond 10 cover the cost of that amount an amount - the same amount wes then — there wes a joumel entry to cover the cost from the Atlantis Motors account so that the balance sheet atthe end of the day could balance with respect fo that transaction that fook place. So the money came {rom the [BARUT] account within the Atlantis Motors and it was for a lack of better word ...then transferred {0 the Atlantis Motors account fo balance the two transactions out’; and “1 phoned her on more than one occasion I think i is at least three ‘occasions requesting an explanation. She said she will revert fo her legal representative. Whether she did or not | do not know Ihave not — hhave not received any correspondence or explanation from her after — after that and after my ~ and alter me folowing up on my request. So 1 60 not know ~ apart from the fact that I can state that ihe money came {rom the [BARUT] account info her account | do not know ~ | do not have any information relating fo the context ofthat payment.” 40. The transcript of the third day of Mir Roelofse's tastimony published by the ‘Commission is attached inthe relevant part, as annex "NM". AR nw, 5 11 2 19, 14, It is these portions of Mr Rosiofse's affidavit and testimony before the ‘Cornmission on which | intend to cross examine Mr Roelotse. Its important for context to consider that though Mr Roeiofse did not refer to sme during his fist day of testimony, on 17 September 2019, he did note that he had been informed that members of crime intligence had paid jouralits from the South Aican Police Secret Service Account ("SEA") te publish and withhold ticles to drive certain naratves. A copy of Mr Roclofse's testimony in relevant part & attached os annex "NMA". These allegations are of importance ae Mr Roelose appears to allege that the joumalisis received money from the SSA in ‘exchange for manipulated media reporting, ‘The above allegations are extremely serious and have the potential to destroy my reputation as a journalist, [the outsot, | wish to make it clar that | deny having been invohed in any act of compton, bribery, fraud or meney laundering, | deny that 1 wrongfully end Lnlawully benefited from state funds as part of an unlawful scheme, 1 had no knowledge of how it came about that detas of a personal transaction of mine wore on the books of Allants Motors. Moreover atthe time of the payments roforred to in Mr Roelfse's statemont, | was not even working as a journals “Tho enti narrative & not only bizare but the conclusion it reaches that | am ‘corrupt or commited any wrongdoing is false. Moreover, Mr Roootse does not state or provide any evidence of what | had done or was expected to do in exchange for payment from the SSA. ¢t porns 8 RELEVANT BACKGROUND Career Background 18 16, 17 18, 19, 20. 24 | have worked in journalism, communications and public relations over the span of my career. | italy started in the journaism space working parttime as @ journals from my ft yoar of studies in 1991 at the SABC and the Sunday Tribune. In 1994, | became a reporter atthe Natal Witness. | then worked es the Media Lisson Officer at the Ministry of Transport in KwaZulu-Natal in 1996. In 1999, | roturned to joumaism, joining the Sunday Times in Durban. 1 ‘subsequently joined the Sunday Times’ polties team In Johannesburg in 2001. | then left he Sunday Times in 2003. In 2004, | worked at This Day until closed down later that year. From October 2004 until Apell 2012, I was no longer working as a journalist, 1 ecided to redirect my attention to the communications and public reations business. Belween 2004 and 2008, Iran my evn communications out, doing public relations, media training and politcal ressarch, From July 2009 to October 2010, | Joined the Deparment of Higher Education and Training as head of Communications, In 2071, | worked at McCann MSP doing public relations. I Joined the Dally Maverick in August 2011 as a sub-ecitor. From April 2012, | ‘began wring for Dally Maverick as a senior journalist and then associate editor. | then joined my current employer Tiso Blackstar, in July 2017 as an Associate Editor: Analysis in July 2017. | write a weekly column for the Sunday Times. a mp Family Background 2, 23. ‘My family comes from Dannhauserin northem KneZulu-Natal 1 was my parent's ‘only chid but our family has hed a very eose relationship with the Abdo! family for many decades. My father was a childhood friend of Ahmed Abdoo! and they chose to live aorss from esch other when we moved to our township around 1980. His wife Zahra Abdool was very close to my mather and she wes ike a ‘second mother to me unt her death in 2003. | conser thei sons to be my bothers, and am particulary close to the youngest of the brothers, Basheer ‘Atwned Abdool (‘Basheer"). We have helped each other financially and otherwise over many years and we are still very close. ‘After my fathor passed away in 1994, I had to leave home to pursue employment ‘opportunities, The Abdool family took care of my mother in Dannhauser and stil {do 50 today, The children regard her as a grandmother. ‘My BMW 330i Convertible 24. In early 2003, 1 was involved in an accident near Standerton with my Toyota MR2, a soft top convertible, Despite the subsequent repair of my Toyota it wes Very unstable on the road, Basheer and | discussed me getting a new car which ‘would afford me grestor safety and stably | know very lis about cars and 0 | relied onthe advice of Basheer. He asked a mutual fiand also resident in Dannheuser and invohed in car sales, Zahir Moosa, to find me a BMW convertible, Zahir ranged the purchase of previously owned BMW 330Ci Convertibi, registration number PMVSESGP. (the BMW". # WweP 8 26. 7. 28 Ey 30, In August 2003, | purchased the BMV through Westank vehicle financing for @ purchase price of approximately R964 698.70. The vehicle was fnanced though Wesbank over @ 60 month period with a balloon payment amounting to approximately R128 935,92 due atthe end ofthe term, | allach a copy ofthe last \Wesbank statement | received prior to seltement ofthe outstanding emount on the vehisle, dated 16 April 2008, marked "NMS". The statement contains the terms of the fancing agreement. The vehicle was registered in my name but \was also used by Basher when Las at home in Dannhauser. In August 2007, | purchased a townhouse in Johannesburg for R810 000 and paid an acceptance fee of R10 000. A copy ofthe Offer to Purchase decument, dated 14 June 2007 is altached marked "NMG". I have redacted the exact adress as | sill own this property and there is no reason thatthe addrese should be made public: | used the proceeds from an insurance poboy to pay @ depost of approximately R145 056.25 forthe purchase ofthe townhouse. | wes granted a home loan from Standard Bank for the outstancing amount of approximately R670 000.00, hich Lam stil servicing Given the financial pressure of scrvcing my naw bond for my townhouse and the fact that my income was not stable as | wos running my own communications business, in or around November 2008 my accountant advised me that it would be prudent to attempt to sete the oustancing loan on my vehicie. He advised that this would allow for more money to be made avalable for my bond payments. We had the conversation again around April 2008 while discussing ny taxes. This wes good advice, On one of his trips to Gauteng (where he used to do business at the fruit and vegetable markets in Johannesburg and Pretoria), ri mh sums 3 at 32, Basher stayod with me and | ciscussed the matter of paying off the debt owed cn my vehicle with him, This would have besn in May 2008, Basheer was atthe time in business as a successful fut and vegotable wholesaler. Upon hearing of my financial predicament Basheer told me not to wory and that he would pay off the outstanding debt on the car himself. At his request | provided him with the ‘account details for my Wesbank vehicle repayments, The understanding betwen Basheer and myself atthe time is that he would sete the belance due directly with Wesbank. He was and stiis @ successful businessman and Kt was not unusual to me thet he would be able fo pay an amount such as the amount which | owed to Wesbank. Basher later advised me that he had paid the outstanding amount of my \Wesbank loan and in due course 1 received statement reflecting the final setlement amount of R143 621.78 [the settlement amount") paid which rellecled on 9 May 2008. A copy of the paymont history reflecting the thal settlement amount paid is allached marked "NM". Apart frm thanking him profusely for assisting me with my fnancal predicament, Basheer and | did not ciscuss this payment again, uni I received the Commission's notice, | have only Since receiving the Commission's notice discussed with him the creumstances in Which he made this payment When I revisited the payment of the settlement amount with Basheer last week, he confirmed that he paid the settlement. | attach the confirmatory affidavit of ‘Basheer, 28 annex "NM&" where he explains that: 32.1. During that period, he was shopping around for another vehicle, He identifed a pre-owned Nissan Hardbody ("Nissan *) at Atantis Nissan in Centurion, The Nissan was at a comparatively good price and so he a me vrs 10 33, 34 decided to purchase it, He paid an amount of approximately F160 000 in cash and was scheduled to collect the Nissan on 9 May 2008, 32.2, In light of my financial predicament on the morning of 9 May 2008 he called the dealership to cancel the sale of the Nissan Hardbody. He was told thal he could not get his cash back but thal the dealership could vansfer the funds into his account. Instoad, he asked the dealership to transfer the outstanding amount forthe balloon payment of R143 621.78 to my Wesbank Vehicle Finance account, He provided the dealership wth the details of this account and my full name, He wes informed that he had to forfeit the balance os a “handling fee" cither fora transfer to his or my account. Basheer was given a prinout of the transfor to my account. He called me later that afteroon to inform me that he had setied the payment, He didnot tll me how he made the payment or that he cancelled the purchase of his Nisan van. | i not know unt now that he had to forfeit a part of the money in oder to hep ime. He says in his affidavit he knows nothing about the allegations that Crime Inteligence was involved at Atlantis Motors. | continued to use the BMI until last year. When my financial situation changed (joined Tiso Biackstar) | purchased a new vehicle, Basheer arranged a driver to pick up the BRIW. He used it in Dannhauser, although it remained registered in my name. Basheer subsequently sold the BMY and he received the payment for at | note that the seltlement amount (which | now know through Basher came from [Alantis Motors) is exactly the same as the amount mentioned by Mr Roetotse, ff wr " Investigations surrounding the BMW 36, a7. 39. 40, a In 2012, while working forthe Daily Maverick I received @ phone call from someone who ldenified himself as a police investigator. | did not get his name, cr 1 did, | cannot now remember i, He had what | identified as an Indian accent “Tho police investigator said fe wanted to come to my residence to talk fo me ‘about an investigation. | dd not Know what this was about and was worried aout alowing @ stranger to come to my house. | arranged that he should come to our office, atthe time at 160 Jan Smuts Avenue in Rosebank. | informed my editor Branko Brkc about this. He waited with me atthe office at the time the police offcer had arrenged to meet me. | recall Greg Marinovich, another associate exitor at the tile, also being there. They wished to show solidarty inthe event that tis was an attempt to intimidate Dally Maverick, The police officer never arrived and | never heard from him again ‘The confimatory affidavits of Branko Brkic and Greg Marinovich will be filed shortly with the Commission, In around 2014, | was contacted by someone who Mdentiied himself as Coloné Roelofse from the Hanks, He sald he was investigating a matter involving my car. | was puzzled about this and asked that he explain. He said he wanted to ‘meet with me. [At the ime, | was suspicious that the enguiry by the policeman was related to the fect the Daily Maverick had been publishing a number of stories crtcal of the police at that time. This Included, infer alla, stories surrounding the Marikana Massacre and the Farlam Commission, and the police's role in the Nkandia ver eran 2 42, 43. upgrades. | was concemed that this may have been some frm of intimidation tactic. | did not know and had never heard of Colonel Rosiotse and | did not understand why anything related to my car would be under investigation Given my reservations | hough i best moet Mr Roelose inthe presence of lawyer. | contacted an atomey tan Smal-Smith, | consultd him and told him about the approach ftom Mr Roeofse, and asked that he be present during the meeting, When Linformad Mr Roelose that! had decided to bring a lawyer wath ime to the meeting, he seemed eurprised. He made no futher contact with me. “This is despite Mr Roeltse underiaking to conf details of the meeting with me during our last exchange. | al file @ confirmatory affidavit of lan Small-Smith with this application. | pote that Mr Roslofso stated in his testimony on Wednesday ‘18 September 2019 that he had mad contact with me at least three times over tne years and he implies that | refused to co-operate wih him or evaded hin. Nothing couls be further from the truth. It was indeed Mr Roelafse who ended cour discussion by stating that he would contact me after | had informed him that | hhad sought legal representation. He never did, orf he did, | have no record or recollection of those approaches whatsoever. SUMMARY OF WHY THE ALLEGATIONS AGAINST ME ARE BASELESS 45, ‘As | have stated above, Ihave been provided with only a portion of Mr Roelofse's affidavit in terms of the Commission's notice and have had access to the transcripts of his evidence to date, | have not been provided with any of the supporting documents or attachments to the affidavit, which ostensibly a yor 46, 47, 48. 8 ‘substantiate the allegations that have been made. | reserve the right to supplement these papers if this becomes necessary. In his atfdavit before the commission, Mr Roelofse states thal a sum of R143 621.78 was pad from the Atlantis Motors account to @ Wesbank Vehicle Finance account in satloment of a vehicle registered in my name, | now know tat this is correct, as | have explained above, but the sinister sein which Mr Roolotse seeks to meke of it is not coeet at al, had no idea that Basher had ‘arranged to pay the settement amount through tants Motors ater canceling the purchase of his Nissan van. Thal was his privat arrangement with Atantis Motors which | knew nothing about. All| knew was that a close family fiend - 3 brother to me = had helped me out with my financial predicament by paying off my Wesbank loan, Basheer was doing me a favour out ofthe goodness of his heart and | was grateful to him. 1 point out that at the time of the payment, being 8 May 2008, | was not @ journalist as implied by paragraph 140.2 of Mr Roelofse's affidavit. | was working for mysaf in commuricatons. Fram October 2004 until April 2012 | wes not working as a jourelist. At the time the BMM's settlement emount was paid, there was no way to predict that | would turn to journalism four years later, much less favour anyone who had paid the settlement amount for me through favourable artces (if that isthe suggestion). Roslofse further slates that “This amount was debited agains the Atlantis Motors [BARUT account on 30 July 2006" | am unsure what this means, It fs common cause that the money was paid to Wasbank on @ May 2008, neatly three months before ites alleged “debited against the so-called BARUT account, | assurne Roolofse is referring to an accounting enity in the books of Atlantis Motors. | a aR 49, 0, “ have not seen any supporting documentation in his regard and cannot comment thereon. | know nothing at all about i. | repeat that | had no idea that Alanis Motors was involved in eny shape or form with my Wesbank loan repayrnent. | further have no knowledge about why there was an almost three month delay between payment ofthe settlement amount andthe supposed “debit entry" inthe books of the Mantis Motors BARUT account, Indeed I have only heard of ‘iiantis Motors es « result of Mr Roiotees testimony However, Atlantis Motors is a legtimate car dealership and any member of the pubic can purchase ‘icles from them without knowledge of how transactions are recorded! in ther books. it beers mentioning that despite Basheer proving my full nae forthe Iransfor the entry in the books was allegedly made under Ranjon! Mlunusamy which fs the name | am publically known by. “The suggestion tha | somehow benefited from a comupt scheme as a journalist hes akady had a destructive impact on me, my career and the media industry. Mi Roslofse does not say what the expectation would have been on mo in exchange for such @ benefit. The fact hat | was not even a journalist asthe time and therefore Mr Roelofse's implication that | corrupted myself as a journals, falls completly flat. This however stains my repultion because ! om presumed to have engaged in wrongdoing | do not understand how the assistance | got in paying off my Wesbank loan from someone who is @ brother to me can remotely constitute “stato capture’, corruption or wrongdoing of any kind, tis the kind of personal favour that fiends and family do foreach other every diy. had ne knowledge whasoover ofthe ‘connection with Atlantis Motors, a An wenn 8 51 82, 53, | have boon advised by the Commission that L-Colonel Dhanajaya Gangulu Naidoo (‘Colonel Naidoo!) has also implicated me. | am also aware that Ccolonet Naidoo n his testimony before the Commission on 30 September 2019 mage further allegations against me, 1 deny the allegation that | was pald by ‘crime Inteligence. deed much of Mr Roelofse's statement is hearsay and comes from Colonel Naidoo. | wil shotly also be filng an application to cross- examine Gute Naidoo end an affidavit with my evidence in that regard. | value my cedibity asa journalist and | am utterly horrfed by the allegations that | have been paid from the SSA. Those allogatlons are entrely baseless and false. | nave no idea of what the motives of those who have accused mo are and why | have been targeted. | stale unequivocally: | have never been in the pay of Crime inoligence, whether as a jourmalis or otherwise. The suggestion that have is preposterous. It has caused me significant distress and anguish. My view is that this is en attempt to destroy my credibility to ensure that | will not be taken seriously 2s a journalist. | wil not et this intimidate me in carrying out my ‘ole af 2 journalist with professionalism, independence and integrity. GROUNDS FOR APPLICATION 54, 55, | am advised that the Commission may recoive any evidence, so long as this ‘evidence is relevant to the mandate of the Commission.” | am also advised that the Chaiperson of the Commission ("the Chairperson") has the discretion, in terms of the Rules of the Commission, to grant leave for ‘an implicated inaridual to Tbe te Gorminons dasion on a Dance Allanca’s requ lo paps the poceadogs of tt ‘omsoon 4 August 2018) par 6) th tA 6 55.1, give evidence before the Commission; and 155.2. to cross-examine the winess who has implicated ther.” 156, The abovementioned discretion is exercised only i ts both necassary and in tho best interests ofthe Commission's work. The Commission has stated that it *afords [tis opportunity] fo every implicated porson, so that they may fll their side ofthe ston/’* 57. IW am granted leave to cross-examine Mr Roslofsa and provide my own evidence to the Commission, | will demonstrate in my submissions to the Commission that the allegations are false and were made without due consideration of the true facts. | respectfully submit that the evidence that | Intend to present to the Commission, and my cross-examination of Mr Roslofse willbe necessary and in the best interests ofthe work of the Commission as It vill assist the Commission in assessing the truthfulness ofthe allegations made Mr Roolofse in relation to me, and, accordingly, the veracity of Mr Roelofse's ‘evidence presented fo the Commission as a whole. 568, Furthermore, the allegations damage my reputation and undermine my dignity. “The allogations are particulary damaging to my reputation as a respected jourmalst. The allegations have undermined my legitimacy and authory a8 @ wolkrespected journalist. Furthermore, | have had to endure scathing media reports questioning my character, motives and abuse on social media posts as 1a result ofthe allegations, a sample of which are attachod as annex "NM" 59. | accordingly wish to make my awn submissions to this Commission and cross- examine Mr Roelofse in order to vindicate my reputation and dignity and in order to prevent futher harm to my reputation. ale 38.8 of te Commies es : wre Doon an th npeaion fr lens Jo caseamine bog by Ajay Kura Gul, ia Rapa Gupte and MrDadcan 2a a8 . eh 60. ” Finally, I wish to stato that | am prepared fo and wish to give my evidence in rebuttal of Mr Roelose's evidence as. mater of some urgency, given the allegations that have been made against me publically and the fact that this is impacting on my career and my wotk. | request that | be accommodated to give my evidence in the next few weeks, as opposed to month. CONDONATION 6 62, 63. 66. | ask thatthe Commission may grant re condonation fr the fat fing of my application and supporting affidavits forthe reasons set out below, ‘As stated above | received the Commissions notice on or about 6 September 2018, | only read the email on Monday 9 September 2019, thinking that the email was one of many I get from the Commission in my capacty as a journalist reporting on the Commission's proceedings | am advised thet paragraph 6 ofthe Commission's notice provides that | must ‘appl to the Commission to give evidence or cross-examine Mr Rosofse within fourteen calendar days of receving the notice being 20 September 2010. 'As I believed and sil do boiove that Mr Roelofs allegations are an attack on ry craft asa journalist | brought thi immediately tothe attention of my editor Bongani Siqoko ofthe Sunday Times. ‘The attomey acting for the Sunday Times Willem de Klerk was tasked with assisting me lo respond to this notice and we had consulted for afew days. However, on 16 September 2019 Willem informed me that Tiso Blackstar had torminated his engagement agreement over the weekend. | then had io find ther legal assistance and secured the services of Duty Milo at Webber \Wentzel Aomeys on or about 16 September 2019. He then hed to brief senior counsel Dumisa Nisebeza SC. Senior counsel was briefed on or about +17 September 2019, | was then only able fo consult with my new attomeys and at ra 18 senior counsel on or about Wednesday. 18 September 2019, The legal tear then began preparing the affidaits. The preparations of the papors were further delayed by the pubic holiday on Tuesday 24 September 2019 and the fact thal my senior counsel was unavailable during the later part of last week Consequently, the earlest the papers could be finalised was. today, 30 September 2018. CONCLUSION 66. Inthe orcumstances, | seek leave to: 66.1. present writen evidenso (captured inthis affidavit) and oral evidence before the Commission: 66.2, tocross-examine Mr Roslotse: and 166.3. be granted condonation forthe late fling ofthis application vanes 9 NAVARI UNUSAMY ‘The deponent has acknowledged that the deponent knows nd understands tho coptents of tig efidav, which was signed and, sworn fo before me at jgnnsiemuter he on this, he TOM day of e 2019, the regulations contained in Government Notloe No. R266 of 21 July 1072, a amended, and Goverment Notice No. R1648 of 19 ‘August 1977, a8 amended, having been complied with pyle rites ETT] rrourteure 7 vai SERVICE CENTRE “COMMISSIONER OF OATHS annnnnuser TA PUNSTAT np fob Designation: Capacity: en Fulnames: 1c%es? Ato bong Starve Business adress: 28 Geratare Phtwo

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