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[2019] ZAGPPHC 220
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Omnia Group Proprietary Limited t/a Omnia Fertilizer v Foskor Proprietary Limited (74266/17) [2019] ZAGPPHC 220 (13 June 2019)
IN THE REPUBLIC OF SOUTH AFRICA
IN
THE HIGH COURTOF SOUTH AFRICA
(
GAUTENG DIVISION, PRETORIA)
(1)
REPPORTABLE:
NO
(2)
OF
INTEREST TO OTHER JUDGES: NO
(3)
REVISED:
YES
CASE NO: 74266/17
13/6/2019
OMNIA
GROUP PROPRIETARY LIMITED
t/a
OMNIA FERTILIZER
APPLICANT/EXCEPTION
And
FOSKOR
PROPRIETARY LIMITED
RESPONDENT
JUDGEMENT
KHUMALO
J
[1]
This is an Exception raised by Omnia
Group (Pty) Ltd (" Omnia" ), the Excipient, Plaintiff in
the main matter, against
a conditional counterclaim delivered by
Foskor (Pty) Ltd ("Foskor"), the defendant (now the
Respondent), together with
is Plea in defence to a summons issued by
Omnia claiming payment of money it alleges to have overpaid for
Phosphoric acid that
Foskor supplied to it in terms of various sale
agreements.
[2]
Foskor is the only local producer of
phosphate rock concentrate in South Africa, from which it also
produces phosphoric acid for
export and local markets. Its facility
is located in Richard's Bay. It is the only supplier to the local
market and its main export
market is India.
[3]
Omnia manufactures and retails
fertilizers like Nitrogen (N), Phosphate [P]and Potassium in granular
and liquid form that is derived
from, inter alia, phosphate rock,
phosphoric acid, MAP and DAP purchased from Foskor. It is the largest
purchaser of Foskor's phosphoric
acid in the country.
[4]
On 28 February 2011, pursuant to a
complaint that was lodged with the Competition Commission about
Foskor's excessive pricing of
phosphoric acid, that it was in breach
of
s 8
(a) of the
Competition Act,
1998
,
the Commission and Foskor
concluded a
consent agreement,
which
was approved by the Competition Tribunal ("the Tribunal")
subject to a number
of
amendments
(included in the addenda).
[5]
The relevant portion of that agreements reads:
"Foskor
undertakes
not
to revert to its past pricing policy for the sale of phosphoric acid,
phosphoric rock, MAP and DAP. This policy comprised of
import parity
benchmark for phosphoric acid which included
national fright
charges to India. Henceforth, Foskor will charge a price based on the
FOB Richards Bay Port in respect of phosphoric
acid.
(my
emphasis)
[6]
A price based on FOB Richards Bay Port
is determined by taking the CFR (Cost and Freight) India price and
deducting freight charges to that
destination.
[7]
The High Court confirmed on 16 October
2015
in
a
judgment and order handed down in a matter between Omnia and Foskor
that the Tribunal Order requires Foskor to charge local customers,
like Omnia, a price for its phosphoric acid that is based on the
FOB
Richards Bay port price, a price equivalent to the export price or
the CFR India price less freight charges.
[8]
For the period September 2014 to date,
Omnia bought,
pursuant to separate
monthly sale agreements concluded partly orally and partly in
writing,
phosphoric acid from Foskor
on an ad hoc basis.
[9]
Omnia alleges that it was an implied
term, alternatively a tacit term, in each of the monthly sale
agreements that in
the event of the
price charged by Foskor exceeding the price which the Tribunal Order
required Foskor to charge domestic customers
for its phosphoric acid,
which is
the FOB Richards Bay port
price (or the CFR India price less freight),
the
price would subsequently be adjusted once the difference had been
confirmed, and any overpayment by Omnia would be remedied
by way of a
reimbursement by Foskor of the amount by which its price exceeded
that permitted by the Tribunal Order.
[10]
According to Omnia since September 2014,
Foskor has not complied with the price mandated by the Tribunal Order
, instead charged
Omnia a considerably higher price. In the case of
all those sales agreement concluded from September 2014 to date, that
had a price
higher than the export price, i.e. greater than the FOB
Richards Bay port price,
there was a
variance between the prices Foskor actually charged local customers
and the prices the Tribunal Order permitted it to
charge them.
[11]
The total difference between the amount
which Foskor was permitted to charge Omnia for its phosphoric acid,
pursuant to the Tribunal
Order, and the amount which Foskor required
Omnia to pay, and which Omnia accordingly paid, from September 2014
to date amounts
to R175 538,056.00 according to Omnia.
[12]
A formal protest
that
the prices which Foskor was demanding for phosphoric acid in that
month was higher than
the price
permitted by the Tribunal Order was on S September 2014 and 19
February 2015 registered by Omnia,
indicating
that payment was made under protest and with full reservation of its
rights to reclaim and recover all amounts in excess
of the FOB
Richards Bay port price.
Foskor
disputed that its prices were in contravention of the Tribunal Order
and insisted that Omnia pay the
price set.
[13]
It says in the light of Foskor's
monopoly
of the local phosphoric
acid market and its control of the only import terminal and Omnia' s
dependence on Foskor's phosphoric acid
Omnia
had no option other than to purchase from Foskor
at
the price demanded by Foskor.
[14]
Omnia points out that in terms of the
implied or tacit term, Foskor is obliged to repay Omnia the amount of
R175 538 056.00, an
amount by which Foskor's prices from the period
September 2014 exceeded the prices permitted by the tribunal order.
[15]
It pleaded in the alternative that
in
the event the court holding that the monthly sale agreements did not
contain an implied or tacit term as pleaded , that Foskor
could not
lawfully charge its local customers such as Omnia a higher price than
the Tribunal Order.
Those agreements
were accordingly illegal and prohibited and accordingly void, and
alternatively invalid and unenforceable. Omnia
involuntarily paid the
amounts demanded by Foskor under protest.
[16]
Furthermore Omnia points out that the
difference between the prices Foskor charged it for phosphoric acid
from September 2014 and
the amounts permitted by the Tribunal Order
was not due and owing to Foskor.
Foskor
was enriched at Omnia's expense and Omnia was commensurately
impoverished from September 2014 to date in the total amount
of R175
538,056.00.
[17]
Omnia therefore seeks an order declaring
void alternatively unenforceable, and setting aside each agreement
between Omnia and Foskor
from September 2014 to date, in which Foskor
charged Omnia a price in excess of the price that the Tribunal Order
permits Foskor
to charge local customers.
[18]
It thereby prays for the Payment of the
amount, and to the extent necessary an order declaring each of the
agreements between Omnia
and Foskor void alternatively unenforceable
and setting them aside.
The Plea
[19]
Foskor has in its Plea pleaded
prescription in respect of the claim for September 2014.
[20]
On the remainder of the claim Foskor has
pointed out that clause 5.4. of the original consent agreement was by
virtue of the unsigned
addendum only applicable for three years post
the granting of the Tribunal Order; and the fact that Omnia's
purchase order expressly
record that "All prices on the order
are firm and not subject to change" that being the basis upon
which Foskor supplied
the phosphoric acid to Omnia.
[21]
Foskor denies that PC3 forms part of the
entirety of the three monthly agreements for phosphoric acid ordered
in October to December
2015.
Also
that it was under any obligation to charge Omnia the FOB Richards Bay
Port price. In the alternative, Foskor pleads that it
was entitled to
charge Omnia a price reasonably related to the economic value of its
goods.
[22) In the further alternative,
Foskor alleges that, to the extent that it was not entitled to charge
the Plaintiff a price reasonably
related to the economic value of its
goods, by supplying its goods to the Plaintiff at the FOB Richards
Bay price,
Omnia was enriched at the expense of Foskor who was
impoverished, as such price was below its costs of production during
the period
September 2014 to date. In respect of each of the month of
September to August 2017 Foskor's cost of production was in excess of
the FOB Richards Bay price in Rands per
ton.
[23] To
the extent that it is found that the Defendant was obliged to charge
Omnia for phosphoric acid at
FOB Richard's Bay Port prices during
September 2014 to date, which it is denied, Foskor denies that it was
enriched by having charged
Omnia prices in excess
thereof,
stating that instead Omnia would have been enriched had it received
the phosphoric acid it purchased at the FOB Richards
Bay port price,
as Foskor's costs of production exceeded such prices for each and
every month concerned, or in fact at any price less than Foskor's
cost of
production.
[24] It
also denies that PCS reflects the amount of R175 538,056.
[25]
Foskor ' s counterclaim is
conditional upon the court finding that Foskor is indeed liable to
make payments to Omnia of any amounts
it charged for phosphoric acid
in excess of the FOB Richards Bay port price for the period September
2014 to
August 2017, alleging
that:
[25.1] For each and
every month over the period November 2014 to October 2017,
Foskor's
cost of production was in excess of the FOB Richards Bay port price;
[25.2] For the months
November 2014 to September 2015, November and December 2015, May to
September 2016 and the month
of February 2017,
Foskor's cost of
production was in excess of the amount it charged Omnia for the
phosphoric acid it purchased.
[25.3]
In the event
Omnia's claim is upheld, Foskor will have been impoverished by being
ordered to make payment to Omnia
in an amount which will result
in it having made a loss over the period November 2014 to October
2017, which would be to Omnia's
benefit.
[25.4] Omnia will
accordingly be
enriched unjustly,
having received goods for a
price lower than their cost.
[25.5] Attached marked
"DP3" is a copy of a table, setting out Foskor's loss per
ton over the period November
2014 to October 2017 based on its costs
of production as against the price it invoiced the Plaintiff as well
as compared to the
FOB Richards Bay price.
[25.6] Foskor's total
loss per month over the period November 2014 to October 2017 based on
its costs of production
as against the price it invoiced Omnia,
amount to a total of R122, 182,023.11 over the period.
[25.7]
Omnia has been enriched by the total amount of R122, 182,023.11 at
Foskor's expense.
[26]
Omnia excepts to the counterclaim on
three grounds, on the basis that Foskor's counterclaim fails to
disclose a proper cause of
action, arguing that:
First Exception:
[26.1] in these
circumstances, in a situation where the court would have found that
Foskor is obliged to reimburse Omnia
in terms of contract or upon the
basis of it having been unjustifiably enriched, then both as a matter
of logic and of law,
Foskor could not have a cognisable claim
against Omnia for unjustified enrichment pursuant to that
reimbursement on the very same
facts.
[26.2] Foskor also
cannot advance cognisable claim for unjustified enrichment, as it
seeks to do, by pleading that it
"will have been impoverished by
being ordered to make a payment to Omnia in an amount which will
result in it having made
a loss over the period November 2014 to
October 2017, which would be to Omnia's benefit."
Foskor
cannot claim to have been unjustifiably impoverished pursuant to a
court order, let alone a court order that redresses unjustified
enrichment of (Foskor) Foskor as against (the Plaintiff) Omnia.
Second Exception:
[26.3] There
exists
a numerous
clausus
of enrichment
condictiones,
and
Foskor is accordingly required to bring its
unjustified enrichment claim within the parameter of one of these in
order for the claim
to be sustainable in law.
Foskor has however
failed to plead its claim in reconvention in a manner that meets the
requirements of any of the recognised condictiones.
Third Exception:
[26.4] Foskor contends
that for every month between November 2014 and October 2017, its
costs of production were in
excess of the FOB Richards Bay port
price. Omnia will accordingly be enriched unjustly, having received
goods for a price lower
than their cost, Foskor will be impoverished
by paying to Omnia an amount (based on the FOB Richards Bay port
price) that will
result in it having made a loss over that period.
[26.5]
Foskor
however is restricted by an order of the Competition Tribunal,
confirmed by two orders of the High Court, to charge local
customers
(like Omnia)
the FOB Richards Bay port price
for its
phosphoric acid, and thus the export price of phosphoric acid ex
Richards Bay.
[26.6] Insofar as
Foskor contends that the Tribunal Order was applicable for only three
years from the date upon which
it was granted, that is incompatible
with the judgments and orders of the High Court under case no:
14554/2015 and A203/16 and
is accordingly , unsustainable as a matter
of law.
[26.7] Whatever the
costs are alleged to be,
Foskor could thus not, as a matter of
law, be unjustly impoverished by being compelled to charge Omnia the
only price for phosphoric
acid that it could legally charge;
and
Omnia could not, as a matter of law, be unjustly enriched by paying
Foskor the price that Foskor was legally obliged to charge
local
customer.
[27]
For this reason, Omnia submits that the
conditional claim in reconvention is
unsustainable as a matter of law
and
prays for the conditional counterclaim to be struck out in
toto.
LEGAL
FRAMEWORK
[28]
In order to succeed with an exception
that a pleading fails to disclose a proper cause of action, the
excipient must show that
on every
possible interpretation that can reasonably be attached to the
pleading (which in this instance is the counterclaim) and
the further
facts, no cause of action or defence is disclosed; see
Coronel
v Gordon Estate Gold Mining
Co.
Ltd
1902
T.S. at p.115;
Sun Packaging
(Pty) Ltd v Vreulink
[1996] ZASCA 73
;
1996 (4)
SA 176
(A) at 183D-F;
Pete's
Warehousing and Sales CCV Bowsink Investments CC
2000
{3) SA 833 (E).
[29]
The test of a valid exception is
therefore, that it must go to the root of the entire pleading
excepted to,
the allegations of which
are assumed to be true for the purposes of the exception.
It
must also assert or imply that the pleading to which the objection is
taken is on the face of it insufficient as a whole, therefore
legally
invalid for its purpose (raising a point of law)
[30]
Omnia's first Exception
is
that Foskor cannot claim to have been unjustifiably impoverished
pursuant to a court order decided upon on the same facts, let
alone a
court order that redresses unjustified enrichment of (Foskor) Foskor
as against (the Plaintiff) Omnia.
[31]
Omnia argues that Foskor,
reliant
on the same facts
upon which the
court would have found for Omnia (Plaintiff), seeks the court to in
turn find against the Plaintiff . The facts Foskor
relies upon are
that the amount settled upon as the price to be charged, which would
have also been confirmed by an order of court,
is less than its
production costs. Alleging that it would be making a loss rather than
a profit charging on that price. As a result,
Omnia will be enriched
by the judgment that the court would have made, that Foskor pay back
the R1 75 000 000.00 an amount allegedly
Omnia paid in excess of the
legal price as fixed (in consensus with it) by the Tribunal. In this
instance the court would have
also decided whether or not indeed it
is so, the onus being upon Foskor to prove if indeed its production
costs factually exceeds
the fixed price as per Tribunal and court
order, and if so, (i) whether even so Foskor has to pay back the over
payment and (ii)
if such a loss can
be legally regarded to be unjust when it arises as a result of a
court decision or legal act?
[32]
The facts to be proven by Foskor are the
same as the facts it had raised in its Plea in defending the
Plaintiff's claim in the summons.
They arise out of the same
transaction and further involves the alleged Foskor's loss
(production costs) and Omnia's alleged benefit
raised in the Plea
which from that perspective, would have been considered when deciding
Omnia's claim. An Excipient, for the purposes
of an exception, is
bound by the pleading to which he excepts and is taken to admit its
correctness, the facts therefore taken
as true; see
Riversdale
Estate Ltd v Mcdonald Briers N.O. and Another
1934
S.R. 51. It will therefore have to be admitted that Foskor's
production costs are in excess of the FOB Richards Bay Tribunal
port
price that Foskor is allowed to charge, and that the amount that
would be paid back to Omnia as per court's order will result
in Omnia
paying less than Foskor's production costs, thus hypothetically
resulting in Foskor suffering a loss. The question would
therefore be
as indicated whether Foskor can thereby legally claim back from Omnia
(the money it has been ordered to pay by the
court to Omnia) its
alleged loss also on the basis of an allegation that Omnia would
unduly/ unjustifiably be enriched by Foskor's
repayment of the excess
payments which Foskor would have already raised in its Plea and
adjudicated upon by the court.
[33]
The circumstances are analogous to
cases, such as those where a defendant admits the plaintiff's
allegations but pleads that as
a matter of law the plaintiff is not
entitled to the relief claimed by him (cf
Welgemoed
en Andere v Sauer
1974 (4) SA 1
(A)),
[34]
Omnia says that it is not only unsound
but illegal to raise the unjustified enrichment claim on the same
facts. The issue of production
costs is raised by Foskor in its Plea
and therefore in deciding the matter as per Omnia's action, the court
would have also considered
the question of unjustified enrichment as
raised by Omnia from the perspective of Foskor's alleged production
costs. The conditional
counterclaim would thus constitute
consideration of same facts.
Foskor
therefore's attempt to then decline immediate repayment as per the
court's order merely by advancing a counterclaim not capable
of
compensation is definitely illogical and not valid in law.
[35]
Once a court has decreed Foskor's
enrichment at the expense of Omnia, to be unjustified on those facts,
another court cannot be
asked to abrogate the order and instead award
Foskor an enrichment order on the same facts. The exception of
res
judicata
did not apply only (a)
where a subsequent action related to an unclaimed item by virtue of
facts unknown to the claimant at the
time of the first action and (b)
where it would benefit the party against whom the judgment was
rendered.
Second Exception
[36]
The crisp of the question being whether
the Defendant can raise a claim on the basis of unjustified
enrichment against a reimbursement
order granted to the Plaintiff by
the court? In
Glenrand MIB Financial
Services (Pty) Ltd
&
Others
v Theodor Wilhelm van der Heever NO
&
Others
[2013]
1 All SA 511
(SCA) by Theron JA and Swain AJA citing with approval
the authors of the Law of South Africa that:
"Although there is no general
action based in enrichment in our law, it is generally accepted that
for enrichment liability
to arise there are a minimum of four
requirements, namely: (1) the Defendant must be enriched; (2) the
Plaintiff must be impoverished;
(3) the Defendant's enrichment must
be at the expense of the Plaintiff and (4) the enrichment of the
Defendant must be unjustified
or sine causa."
[37]
It is argued on behalf of Omnia that
Foskor fails to make out a cognisable unjustified enrichment claim
even on these four standard
requirements. Omnia alleges that Foskor
if seeking redress for an unjustified enrichment must aver and prove
at least each of those
four requirements, subject, to the specific
requirements of the
condictio
in
question. It argues that:
[37.1] Omnia would not have
been enriched by being granted a judgment in its favour by obtaining
restitution of an anterior
loss proven to the satisfaction of the
court. Consequently absent enrichment, Foskor has no claim of
unjustified enrichment.
[37.2] Even if accepted that
there was impoverishment, whatever correlative enrichment there was,
would not have been unjustified
or
sine causa.
A causa being
the court's judgment in question. It argues that
Foskor's actual
production costs cannot affect this analysis.
[38]
Foskor argues that one of the
condictiones
applicable
to the facts, is its impoverishment, therefore the matter ought to be
determined at trial and it would be premature to
reject Foskor's
conditional counterclaim of hand when an enrichment is capable of
being determined at trial.
[39]
The matter as this stage is not
concerned about the merits of the case but the pleading excepted to,
as it stands. The facts in
the pleading are admitted as correct for
the purposes of an Exception. The Excipient is bound by the pleading
to which it excepts
and taken to admit those facts. Therefore Omnia's
Counsel's argument that the actual production costs cannot affect the
analysis
is wide of the mark. What Omnia must prove is that the facts
notwithstanding being admitted, do not in law establish any
sufficient
factual basis to sustain a cause of action or defence as
the case may be. It is therefore accepted that Foskor factually would
suffer a loss due to its production costs being higher than the
amount it is to legally charge for the phosphoric acid as a result
of
the judgment that it pays back the amount Omnia was illegally charged
in excess of the FOB Richards Bay export port price. Does
this give
rise to a valid conditional counterclaim on unjustified enrichment?
Can as a matter of law such a loss which is alleged
to arise due to a
court order on the basis of illegality of agreement or unjustified
enrichment be recoverable on the grounds of
enrichment (benefit) that
is unjustifiable and without a just cause.
[40]
Besides the argument that the same facts
would have been considered already (the counterclaim being
conditional on the court's finding),
the court cannot abrogate its
own decision on the same facts in favour of the offending litigant.
Generally as well,
the court has no
power to relieve parties from the consequences of an unreasonable
contract or one that, due perhaps to unforeseen
circumstances has
turned out more onerous than expected,
it
will take such matters into account in deciding whether to order
specific performance.
[41]
In
Haynes v Kingwilliamstorm Municipality
1951(2) SA 371 (A)
378H-9A De Villiers AJA gave as examples of good and sufficient
grounds for refusing specific performance:
"Where it would operate
unreasonably hardly on the Defendant or where the agreement giving
rise to the claim is unreasonable,
or where the decree would
produce injustice, or would be inequitable under all circumstances .
[42]
It is not every illegal contract which
necessarily entails the rigid penalty that a party to it, is unable
to obtain any relief
whatever from the court. The courts will come to
the rescue of one of the parties where such a course is necessary in
order to
prevent an injustice, or to satisfy the requirement of
public policy.... But public policy does not rest upon the evidence
of any
party. It exist s as a fact just as much does the air which
man breathes; see
Klokow v Sullivan
2006 (1) SA 259.
[43]
The implication of the order of court
would be that Foskor illegally charged Omnia in excess of the legal
price that has already
been confirmed by the court of law in 2015 to
be the legal price that Foskor should charge. In essence it would be
finding Foskor
to be in contempt of the court order. As a result
thereof the sale agreements charging more would have been set aside
by the court
in ordering that the Tribunal price be applicable and
Omnia be reimbursed the excessive payment it made, finding Foskor to
have
been delinquent notwithstanding Foskor's alleged loss.
The
sale agreements accordingly illegal and prohibited and thus void, or
alternatively invalid and unenforceable.
In
order to challenge the alleged inequitable consequences arising from
the court's order setting aside of the agreements, Foskor
should not
be coming to court with dirty hands or it should conversely prove
Omnia to be equally guilty (in delicto); see
Jajbhay
v Cassim
1939 AD 537
where it was
concluded that 'a party seeking to extricate himself from the
consequences of an illegal immoral contract had to demonstr
at e that
he had come to court with clean hands.' The courts implored to
discourage illegal transactions.
[44]
The principle to relax the rule to
prevent inequities has been mooted where it is necessary to prevent
an injustice or to promote
public policy; see Christie "The Law
of Contract in South Africa 4
th
edition at 459-465, recognising that its strict enforcement may
sometimes cause inequitable results. One such instance would be
where
the Defendant would be unjustly enriched at the Plaintiff's expense.
Further in Jajbhay as per STRATFORD CJ at 545, it was
explained that
"Where public policy is not foreseeable affected by a grant or
refusal of the relief claimed,...a Court of
law might well decide in
favour of doing justice between the individuals concerned and so
prevent unjust enrichment. But this can
only be in the instance were
both parties are equally guilty. Whereupon once Foskor has alleged
and proved that Omnia is also in
delicto,
it is then for Foskor to allege and
prove facts that will enable the court to come to its assistance
because justice and public
policy so require.
[45]
However in this case the parties'
conduct has not been portrayed as to be equally morally or otherwise
reprehensible. Foskor had
in contempt of an order of the Tribunal it
consented to and of the court in 2015, also besides the protestation
by Omnia continued
to charge the prohibited price. In addition, as it
would have been found by the court, that a claim that would result in
a charge
in excess of the FOB Richards Bay port price would be
illegal and or unjustifiably enrich Foskor entitling Omnia to be
reimbursed.
Therefore the court would then have declared the sale
agreements invalid or Omnia entitled to repayment of what it has
overpaid
as per the tacit or implied term which Foskor would have
been found to have breached. The court would have found that it is
due
to Foskor's reprehensible conduct that the sale agreements are
invalid . In that instance the cause based on an injustice of Foskor
suffering a loss or on the basis of public policy or inequitable
consequences would not be open to Foskor.
[46]
Foskor is legally prohibited from charging any other price as the
court would have found and decided
upon the correct legal price to be
charged notwithstanding the alleged loss. Any demand for any price
higher would be in deviation
from the ordered price and unlawful. It
therefore would not have a sustainable unjustified enrichment
counterclaim if judgement
is granted against it.
[47] Omnia
had succeeded in showing that the Foskor had failed to disclose a
sustainable cause of action.
[48] Under
the circumstances
1.
The exception is upheld.
2.
The Respondent's Counter claim is struck
out in
toto
with
costs, such costs to include the costs of two counsel as per relief
sought.
NV
KHUMALOJ
JUDGE OF THE HIGH COURT
GAUTENG
DIVISION, PRETORIA
For the Plaintiff/Excipient:
PBJ FARLAM SC
JJ MEIRING
Instructed
by
FALCON & HUME INCORPORATED
C/O FRIEDLAND HART SOLOMON &
NICOLSON
Tel: 012 424 0200
Ref:
Gerhard Painter
For the Defendant/ Respondent :
ANTON KATZ S.C
SANDRA FREESE
Instructed by
:
SHAHEEM SAMSODIEN
ATTORNEYS
Ref: Samsodien
C/O SAVAGE JOOSTE & ADAMA
Tel: (012) 452- 8200
Fax: (012) 452 8201
Email: fllorett
es@savage.co.
za