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[2021] ZAGPPHC 267
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Maguwada and Others v KPMG Services (Pty) Limited SA (22014/2019) [2021] ZAGPPHC 267 (6 May 2021)
IN THE HIGH COURT OF
SOUTH AFRICA
(GAUTENG LOCAL
DIVISION, PRETORIA)
CASE NO: 22014/2019
REPORTABLE
: NO
OF INTEREST TO OTHER
JUDGES:
NO
REVISED.
YES
Date:
2021-05 -06
In the matter between:
NDITSHENI NELLY
MAGUWADA
First to Sixtieth Plaintiff/Respondents
& 59 Others
And
KPMG SERVICES (PTY)
LIMITED) SA
Defendant/Excipient
Delivered:
The
judgment is delivered electronically via email and thus deemed to be
delivered on 6 May 2021.
Summary
:
Claim arising out of pure economic loss, the question of wrongfulness
is quintessentially a matter that is capable of being decided
on
exception, claim by employees and /or shareholders of a company
against the auditors based on alleged negligence in the manner
in
which they conducted an audit of a company is bad in law,
imposing
a legal duty on auditors in claims of this nature raises the spectre
of indeterminate liability.
The general principles governing exception(s) restate.
JUDGMENT
YENDE,
A.J
Nature
of the proceedings
[1]
Before
court is an exception by the excipient /defendant in relation to the
plaintiff’s amended particulars of claim effected
by the
plaintiffs/respondents. The excipient/defendant has delivered an
exception to the plaintiff’s amended particulars
of claim in
terms of Rule 23(1) taking exception to the plaintiff’s amended
particulars of claim. The excipient/ defendant
contends that the
plaintiffs/respondents amended particulars of claim do not contain
sufficient averments to sustain a cause of
action and/or are vague
and embarrassing premised on seven complaints and that the plaintiffs
claim falls to be determinable at
the exception stage.
[2]
The
plaintiffs are former employees of Venda Building Society “VBS”
Mutual Bank. In October 2018, the plaintiffs were
retrenched by Venda
Building Society’s curator. Following their retrenchment, the
plaintiffs brought an action against the
defendant/excipient KPMG
Services (Pty) Ltd “KPMG” claiming damages amounting to
approximately R230 million arising
out of an alleged negligent audit
by the KPMG for the financial statements of “VBS” Bank
for the year ending 2017.
[3]
It
is the plaintiffs case that KPMG were VBS’s appointed auditors
for the financial year ending March 2017.The plaintiff’s
claim
arises from an alleged misstatement by KPMG of the 2017 “VBS”
financial statements, but for which ,they allege,
they would not have
been retrenched.
[4]
In
the particulars of claim the plaintiffs allege
interalia
that; a certain Mr Malapa, a Director and/or an employee of KPMG
conducted an audit, prepared the “VBS” financial
statements and issued an auditor’s report. Acting within the
scope of his employment, Mr Malapa misstated “VBS”’s
financial position and failed to comply with Generally Acceptable
Accounting Practice (“GAAP”). Had KPMG and/or its
Directors complied, the 2017 financial statements would have
accurately represented “VBS” financial position,
alternatively
would have contained a qualified audit. Thus he acted
negligently with the knowledge of the misstatement. The plaintiffs
further
contend that KPMG or its Director Mr Malapa acting in the
course and scope of his employment gave a regulatory audit opinion
which
KPMG and/or its Directors knew was false.
[5]
The
plaintiffs further alleges that had the 2017 “VBS”
financial statements accurately represented “VBS”’s
financial position , the Reserve Bank and the Minister of Finance
would have appointed an investigator and entered into a “resolution
plan” to ensure that “VBS” was not liquidated and
that the plaintiff’s employment could have been secured.
[6]
The
plaintiff’s accordingly claim damages against KPMG in the sum
total of R 230 014 925.20, which comprises :
[6.1] R 60 million
for emotional shock (R 1 million each)
[6.2] R 450 000 for
psychological treatment (5 consultations each, at R 1 500)
[6.3] R 169 564 925.20
for loss of earning capacity caused by the loss of their employment,
and the phobia they have developed towards
the banking sector.
[7]
The defendant/excipient, KPGM seek to attack the plaintiff’s
particulars of
claim on seven separate grounds the most relevant
parts of which are reproduced herein below and do not follow the same
order as
in the exception itself;
The
excipient/defendant argues that the central respects in which the
plaintiff’s amended particulars of claim fail to disclose
a
cause of action are two-fold:
[7.1] Firstly, the
defendant contends that, even if it is assumed that the defendant
culpably caused the plaintiff’s
loss, such conduct is not
wrongful, in that auditors do not owe a legal duty to the employees
of the companies that they audit;
and
[7.2] Secondly,
that on the facts pleaded by the plaintiffs, the defendant is not the
factual or legal cause of their loss,
which is accordingly too remote
from the defendant’s conduct for liability to accrue.
Accordingly on the facts pleaded by
the plaintiffs, the factual cause
of the harm they allegedly suffered was VBS, alternatively VBS’s
curator and not VBS’s
auditors and that the legal cause of harm
they allegedly suffered was VBS, alternately VBS’s curator.
[7.3] Thirdly, with
regards to the alleged misstatement the defendant contends that same
lack averments necessary to sustain
a cause of action and/or are
vague and embarrassing. This lack of clarity is compounded by the
fact that, elsewhere in the plaintiffs
amended particulars of claim ,
the plaintiffs allege that the defendant’s impugned conduct is
that it failed to present fairly
the financial position of VBS “and
misrepresentation of VBS net worth reflecting R 413 965 855.59 and R
4 302 941.99”.
The defendant further contends that In respect
of the alleged “misstatement by Mr Malapa”, the
plaintiffs do not plead
what the misstatement is, they have also not
pleaded what is it that the defendant is alleged to have known
or/ought to have known
and how it is that the defendant acted
deliberately.
[7.4] The fourth
ground of defendant exception is on fault whether in the form of
negligence or intention. According to the
defendant, the plaintiffs
in their particulars of claim contend that the defendant acted
negligently, with knowledge of misstatements.
However it is not clear
whether the alleged failure to comply with Generally Acceptable
Accounting Practice (“GAAP”)
is what the plaintiff
contends amounted to negligent conduct or whether negligence is
pleaded in addition to the alleged failure
to comply with (“GAAP”).
The defendant is accordingly unable to ascertain the nature of its
alleged negligence and
is unable to plead thereto.
[7.5] The
defendant’s fifth ground of exception is on harm. According to
the particulars of claim, the plaintiffs alleges
that as a result of
the defendant’s conduct, they have suffered “
depression,
mood swings disorder, post –
traumatic stress disorder
and phobic response towards VBS issues
”. Defendant contends
that it is unable to ascertain which of the plaintiffs is alleged to
have suffered which conditions
and is unable to plead thereto.
Accordingly no material facts have been pleaded by the plaintiffs
upon which they based their allegation
that these conditions resulted
from their retrenchment, which, in turn, resulted from the
defendant’s conduct or omission.
[7.6] The
defendant’s sixth ground of exception is on damages. The
defendant contends that these damages pleaded by
plaintiffs as
mentioned
supra
are not sufficiently particularized to comply
with Rule 18(10) and are not competent in law. Accordingly
plaintiffs have
stated such damages as a globular amount resulting in
the defendant being unable to reasonably assess their quantum.
Defendant
further contends that these damages for emotional shock are
not competent as the plaintiffs have not alleged that they have
suffered
a detectable psychiatric injury or lesion, and have not
pleaded the material facts upon which they allege that such injury or
lesion
occurred or that it was reasonably foreseeable in the
circumstances. According to the defendant the damages for loss of
earning
capacity are not competent, as there is no basis in law for a
claim of loss of future earning capacity arising from a retrenchment.
[7.7]
The seventh ground of defendant’s exception is on the breach of
Constitutional Rights. In their amended particulars
of claim, the
plaintiffs plead that the defendant has infringed their
constitutional rights and that the action raised Constitutional
issues. Plaintiffs pleaded
interalia
,
that section 34 of the Constitution guarantees the plaintiffs the
right to have disputes that can be resolved by application of
law
decided in a fair, public hearing before the Court, that the matter
infringes on their socio-economic rights such a the right
to housing
,food and healthcare. Further on, that the matter also infringes on
plaintiffs “
protection
against arbitrary loss of employment (property) afforded under
section 25 of the Constitution
”.
The plaintiffs also plead that the Court must determine whether the
defendant has breached the Constitution and that they
seek a
declaratory order that it has done so as per prayer1. The defendant
contends that plaintiffs are unable to rely on the constitutional
provisions they say are implicated in that Section 25 of the
Constitution does not protect against arbitrary loss of employment.
Accordingly an infringement of Section 34 of the Constitution is not
borne out by the pleadings. Defendant further contends
that
there is no basis for the plaintiffs to seek a declaratory order to
this effect, or to rely on Section 172(1)(a) of the Constitution
or
to rely on section 38 thereof.
General
principles
[8]
Rule
23(1) provides
that:
“
Where
any pleadings is vague and embarrassing or lacks averments which are
necessary to sustain an action or defence , as the case
may be, the
opposing party may ,within the period allowed for filling any
subsequent pleading, deliver an exception thereto and
may set it down
for hearing in terms of paragraph (f) of subrule (5)of rule 6:
Provided that where a party intends to take an exception
that a
pleading is vague and embarrassing he shall within the period allowed
as aforesaid by notice afford his opponent an opportunity
of removing
the cause of complaint within 15 days: Provided further that the
party excepting shall within 10 days from the date
on which a reply
to such notice is received or from the date on which such reply is
due, deliver his exception”.
[9]
As described in
Trope and Others v South Africa Reserve Bank
(614/91) [1993]ZASCA54;1993(3)SA264(AD) , explained in Telematrix
(Pty) t/a Matrix
Vehicle Tracking v Advertising Standards Authority
2006(1) SA 461(SCA) para[3] and confirmed by the constitutional Court
in H v
Fetal Assessment Centre
2015 (2) SA 193
(CC)
“
the excipient has to satisfy the court that the conclusion of law
for which the plaintiff contends cannot be supported on every
interpretation that can be put upon the facts”.
Moreover,
an excipient is required to establish serious prejudice unless the
alleged vague and embarrassing material is expunged
(see Barloworld
Logistics Africa (Pty) Ltd v Ford
2019 (5) SA 133
(GJ)). Both the
Counsel for excipient/defendant and plaintiffs/respondents have
presented very good heads of argument in support
of their cases and
the court has borrowed to a larger extent from both the excipient’s
/defendant’s and the plaintiff’s/respondent’s
heads
of argument in setting out the court analysis as it will appear later
in this judgment .
[10]
The Plaintiffs claim is for Delictual liability against “KPMG”
who was erstwhile “VBS” auditors in
relation to an
alleged misstatement of financial statements by a certain Mr Malapa
one of its director(s). The Plaintiffs claim
is by employees of “VBS”
claiming Delictual claim against the auditors of “VBS”.
[11]
The
counsel for the excipient/defendant contends that since the
Plaintiffs/respondents claim is for pure economic loss, the
exceptions
to the plaintiffs amended particulars of claim falls to be
upheld on the question of wrongfulness in that same does not show
wrongfulness
or causation. On the other hand the plaintiffs’
counsel contends that contend the plaintiffs’ claims is of
public interest
and submit that in applying the principles set out in
Standard Chartered Bank matter in the present case, the court should
be loath
at an exception stage “
to
hold that it is inconceivable that Mr Malapa who knew of the
misstatement in 2017 financial statement and audit opinion and who
also knew that his has a duty to report the matter to the regulator,
would not have a duty to speak
”.
[12]
Against
this background, the court will not deal with all the seven
exceptions raised by the excipient, Defendant but will focus
on the
main which is wrongfulness.
Exception
1: wrongfulness.
[13]
I
have borrowed extensively from the excipient heads of argument in
setting out the courts analysis in this regard.
[14]
In
its amended particulars of claim, the plaintiffs plead that KPMG
acted wrongfully, in that it breached its duty to “VBS”
and its employees ,
interalia
to
present fairly the financial position of ‘VBS’.
Wrongfulness is an element of Delictual liability and our Courts
have
been at pains to caution that it should not be confused with the
requirement of fault (whether in the form of negligence of
intention)
(
see
Loureiro and Others v Imvula Quality Protection (Pty) Ltd
2014 (3) SA
394
CC para 53; MTO Forestry (Pty) Ltd v Swart NO
2017 (5) SA 76
(SCA) para 17
.
As the Constitutional Court has confirmed, “(n) egligent
conduct giving rise to damages is not …actionable
per ser.
(see
Trustees,
Two Oceans Aquarium Trust v Kantey and Templer (Pty) Ltd 2006 (3) 138
(SCA) para 10).
[15]
The
test for wrongfulness therefore assumes that the defendant acted
culpably (negligently or willfully) and asks whether, given
that
assumption, the law ought to impose liability. This question turns on
considerations of public and legal policy-the so called
legal
convictions of the community .In so far as the inquiry is concerned
with reasonableness, it is concerned not with the reasonableness
of
conduct, but instead with the reasonableness of imposing liability
(see
Le Roux and Others v Dey (Freedom of Expression Institute and
Restorative Justice Centre as Amici Curiae)
2011 (3) SA 274
(CC) para
122.
Put differently, the wrongfulness inquiry asks whether the law
imposes liability by recognizing a legal duty on the part of the
defendant to prevent the specific harm that the specific plaintiff
suffered
(see
Van der Bijl v Featherbrooke Estate Home Owners Association (NPC)
2019 (1) SA 1
(CC) para 7-11).
[16]
Wrongfulness
thus “
typically
acts as a brake on liability, particularly in areas of the law of
delict where it is undesirable or overly burdensome
to impose
liability”
(see
Country Cloud Trading CC v MEC, Department of Infrastructure
Development
2015 (1) SA 1
(CC) para 20).
That is, it determines whether the infliction of culpably caused harm
demands the imposition of liability or conversely
,
“
whether
the social, economic and other costs are just too high to justify the
use of the law of delict for the resolution of the
particular issue”
(see
Country Cloud Trading CC above).
[17]
As
mentioned above, the plaintiffs’ claim is for pure economic
loss. Accordingly, the law of delict does not allow for the
recovery
of pure economic loss as a general rule. It is not prima facie
wrongful (
see
Home Talk Developments (Pty) Ltd and Others v Ekurhuleni Metropolitan
Municipality
2018 (1) SA 391
(SCA) para1; Itzikowitz v Absa Bank Ltd
2016 (4) SA 432
(SCA) para 8)
.
It is wrongful only if the court determines, on the grounds of public
policy, that the perpetrator should be rendered liable in
delict to
compensate the victim for its pure economic loss. Indeed, in cases of
pure economic, “
the
law proceeds from the precautionary premise of excluding
liability…unless there are good reasons to recognise
liability”
(see
Van der Bijl v Featherbrooke Estate Home Owners Association (NPC)
2019 (1) SA 642(GJ)
para 17).
[18]
The
Constitutional Court explained in
Country
Cloud Trading CC v MEC, Department of Infrastructure Development
2015
(1) SA 1
(CC) para 22-23
that “
Wrongfulness
is generally uncontentious in case of positive conduct that harms the
person or property of another. Conduct of this
kind is prima facie
wrongful. However, in cases of pure economic loss-that is to say
where financial loss is sustained by a plaintiff
with no accompanying
physical harm to her person or property – the criterion of
wrongfulness assumes special importance.
In contrast to cases of
physical harm, conduct causing pure economic loss is not prima facie
wrongful. Our law of delict protects
rights and, in cases of non-
physical invasion, the infringement of rights may not be as
clearly as in direct physical infringement.
There is no general right
not to be caused pure economic loss. So our law is generally
reluctant to recognise pure economic loss
claims, especially where it
would constitute an extension of the law of risk of ‘liability
in an indeterminate amount of
an indeterminate time to an
indeterminate class”.
[19]
Particularly
in cases of pure economic loss, the question of wrongfulness is
regularly determined on exception (
see
Telematrix (Pty) Ltd t/a Matrix Vehicle Tracking and Advertising
Standards Authority SA
2006 (1) SA 641
(SCA) )
.Indeed the SCA has repeatedly tested claims for novel categories of
pure economic loss on exception, explaining that ,given the
novelty
of the claim and the clear legal principles involved ,it is
quintessentially a matter that is capable of being decided
on
exception
(see
Itzikowitz v Absa Bank Ltd
2016 (4) SA 432
(SCA).
[20]
Recently
the SCA in
Hlumisa
Investments Holdings (RF) Ltd and Another v Kirkinis and Others (Case
no 1423/2018)
[2020] ZASCA 83
(03 July 2020)
where it dealt with an appeal from this Division arising from claims
for novel categories of pure economic loss upheld on exception,
stated the following in paragraph 22, “
In
deciding an exception a court must take the facts alleged in the
pleadings as being correct. It is for the excipient to satisfy
the
court that the conclusion of law set out in the particulars of claim
is unsustainable. The court may uphold the exception
only if it
is satisfied that the cause of action or conclusion of law cannot be
sustained on every interpretation that can be put
on those facts. As
Harms JA noted in Telematrix, exceptions are a useful tool to ‘weed
out’ bad claims at an early
stage and unnecessarily technical
approach is to be avoided. The facts are what must be accepted as
correct; not the conclusions
of law”.
[21]
The
SCA in the
Hlumisa
matter mentioned above at paragraph
63-65
,
further stated that “The test for wrongfulness should not be
confused with the factual requirement .The test assumes that
the
defendant acted negligently or willfully and asks whether, in the
light thereof, liability should follow.
[22]
The
appellants submitted that it would not be appropriate to decide
wrongfulness on exception. In this case, as in all cases in
which a
plaintiff claims damages for pure economic loss, it is incumbent that
the facts upon which such a plaintiff relies for
its contention that
the loss was wrongfully caused to be pleaded. The pleadings are thus
the high-water mark of its case on wrongfulness.
In
Telematrix (Pty) Ltd t/a Matrix Vehicle Trading v Advertising
Standards AUTHORITY
[2005] ZASCA 73
;
2006 (1) SA 461
(SCA) para 2
this
court noted that it has often determined wrongfulness on exception.
[23]
In
Telematrix, para3, Harms JA
said
that ‘[s]ome public policy considerations can be decided
without a detailed factual matrix, which by contrast is essential
for
deciding negligence and causation ’.
In
AB Ventures Ltd v Siemens Ltd
[2011] ZASCA 58
;
2011 (4) SA 614
(SCA)
para 5, Nugent JA
noted that in a case such as this, the issue of wrongfulness is
‘quintessentially a matter that is capable of being decided
on
exception’. In the present case all the policy factors upon
which a decision would rest are known.
[24]
In
4(3) Lawsa 2 ed para 4 the following appears:
‘
If
the auditors perform their work negligently, it is the company, and
not its members, that is the proper plaintiff to sue for
any loss
caused to it by that negligence’.
[25]
Auditors are accountable to shareholders collectively, as a body,
i.e. as the company. Put differently,
when auditors make negligent
misstatements concerning the company’s financial statements
,individual shareholders do not
have claims against the auditors ,
because financial statements are not prepared for the benefit of
shareholder’s individual
investment decision . Instead, primary
purpose of auditing accounts is to report on the stewardship of the
directors to the shareholders
as a body, in order ‘to provide
shareholders with reliable intelligence for purpose of enabling them
to scrutinize the conduct
of the company’s affairs and to
exercise their collective powers to reward or control or remove those
to whom that conduct
has been confided’
(Caparo
Industries plc v Dickman
[1990] UKHL 2
;
[1990] 2 AC 605
at 630)
.
The purpose of audit reports is neither to protect the interests of
investors nor individual shareholders”
[26]
The SAC continues to state that “
Imposing
a legal duty on auditors in a case such as this raises the spectre of
indeterminate liability. Policy considerations require
that liability
in delict be confined to reasonably predicable limits (
15
Lawsa 3 ed par 87
).
Limitation of liability is therefore a key policy consideration in
deciding whether pure economic loss should be actionable.
This court,
citing
Gaudron
J in Perre v Apand (Pty) Ltd
[1999] HCA 36
;
(1999) 198 CLR 180
(HC of A) para 32, in
Fourway Haulage
,
said that [t]he first policy consideration is the law’s concern
to avoid the imposition of liability in an indeterminate
amount for
an indeterminate time to an indeterminate class’; and that
liability would be more readily imposed for ‘a
single loss of a
single identifiable plaintiff occurring but once and which in
unlikely to bring in its train a multiplicity of
actions’.”
Discussion
[27]
It follows from the above that the plaintiffs claim is for pure
economic loss and as such the
question of wrongfulness can be
determined on exception. The conduct of the defendant which is
alleged to have caused the pure
economic loss to the plaintiffs
should be classified as wrongful. For the conduct of the Auditors of
“VBS” to be so
classified as wrongful same would require
a judicial determination based on considerations of public and legal
policy. In light
of the general principles mentioned above and
coupled with the recent SCA court decision in the Hlumisa matter
mentioned herein
the court is inclined to uphold the exception.
[28]
The critical question is whether considerations of public and legal
policy dictates that the
auditors of “VBS” the KPMG
should be held liable to the employees of “VBS” for the
losses they have suffered.
In answering this question one will have
enquire as to whether KPMG breached a legal duty to the employees of
“VBS”.
It is trite that auditors are accountable only to
the companies they audit and not to the shareholders or even to the
employees
of such a company. The SCA explained this in
Axiam
Holding v Deloitte and Touché
2006 (1) SA 237
(SCA) para 18
and confirmed it in Cape Empowerment Trust Ltd v Fisher Hoffman
Sithole
2013 (5) SA 183
(SCA) para 21
as follows “
It
is universally acceptable in common-law countries that auditors ought
not to bear liability simply because it might be foreseen
in general
terms that audit reports and financial statements are frequently used
in commercial transactions involving the party
for whom the audit was
conducted (and audit reports completed) and third parties. In
general, auditors have no duty to third parties
with whom there is no
relationship or where the factors set out in the Standard Chartered
Bank case…are absent”.
[29]
The Plaintiffs contends that they suffered pure economic loss because
a certain Mr Malapa, Director
of KPMG knew of the misstatement in the
2017 financial statement and audit opinion as such he had a duty to
report the matter to
the regulator . I submit that this allegation
does not show wrongfulness and the SCA in the
Hlumisa
matter mentioned above held at para[ 67] that “…
where
auditors make negligent misstatements concerning the company’s
financial statements, individual shareholders do not
have claims
against the auditors , because financial statements are not prepared
for the benefit of shareholders ‘individual
investment
decision
”.
I submit that in the present case the corollary applies to the
employees of “VBS”. The financial statements
are not
prepared for the individual benefit of the employees, they are
prepared for the benefit of the company, thus no legal duty
is owed
by the auditors to the employees and no claim is competent on the
part of the employees for any misstatement.
[30]
The court is of the firm view that to recognise the claim of the
employees would go against the
caution raised by the SCA in
Fourway
Haulage
mentioned above where the SCA held that “[t]
he
first policy consideration is the law’s concern to avoid the
imposition of liability in an indeterminate amount for an
indeterminate time to an indeterminate class’; and that
liability would be more readily imposed for ‘a single loss
of a
single identifiable plaintiff occurring but once and which is
unlikely to bring in its train a multiplicity of actions’”.
[31]
When applying the above principles and case law, I am of the view
that just on the exception
on wrongfulness the facts pleaded, as I
have outlined above, for the reasons stated, the excipient /defendant
owes the plaintiffs
no legal duty in law and the Plaintiffs claim is
convoluted and prejudicial to the excipient and untenable at the
level of law.
[31]
In the result the following order is made;
[31.1]
The excipient/defendant’s exception is upheld;
[31.2]
The plaintiffs/respondents are hereby granted leave to amend their
particulars of claim within one month of the date
of this order;
[31.3]
If the plaintiffs/respondents do not so amend their particulars of
claim, their claims against the
excipient/defendant are struck out
with costs; and
[31.4]
The plaintiffs /respondents are to pay the excipient’s/defendant’s
costs of exception.
J YENDE
Acting Judge of the High
Court
Gauteng Division
Delivered: This
judgment was prepared and authored by the Judge whose name is
reflected above, and is handed down electronically
by circulation to
the parties legal representatives by email and uploading same to the
electronic file of this matter on Caselines
The
date for hand-down is deemed to be: 6 May 2021.
FOR
EXCIPIENT/DEFENDANT:
ADVOCATE
S Budlender SC
ADVOCATE M Mbikiwa
(CHAMBERS, Sandton)
EXCIPIENT’S/DEFENDANT’S
ATTORNEYS: BOWMAN GILFILLAN
Sandton,
Johannesburg
C/O
ANDREA REA ATTORNEYS
Pretoria
FOR
THE PLAINTIFFS /RESPONDENTS: S.O RAVELE ATTORNEYS –
MAKHADO
Mr SO Ravele
(Attorney)
Ms IM Khosa (Attorney)
C/O
S.O RAVELE ATTORNEYS
Pretoria