IN THE HIGH COURT OF SOUTH AFRICA
EASTERN CAPE DIVISION, GQEBERHA
NOT REPORTABLE
Case No.: 1069/2024
In the matter between:
ADEL DOREEN McQUARRIE N O
(ESTATE: ALEXANDER MORRISON BELL) Applicant
and
THE MASTER OF THE HIGH COURT , GQEBERHA First Respondent
JAN HENDRIK NEL Second Respondent
HEIDI SWART Third Respondent
ADEL DOREEN McQUARRIE NO
(THE BELL FAMILY WILL TRUST: MT 2899/2020) Fourth Respondent
MARINDA CHRISTINA SUTHERLAND N O
(THE BELL FAMILY WILL TRUST : MT 2899/2020 ) Fifth Respondent
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JUDGMENT
EKSTEEN J:
[1] This matter arises from the administration of the deceased estate (the estate) of
Alexander Morrison Bell (the deceased). Friction between certain of the heirs (the
second respondent, Jan Hendrik Nel, and the third respondent, Heidi Swart ) and the
applica nt, the testamentary executrix in the estate, prompted a request to the first
respondent, the Master of the High Court, Gqeberha , for the removal of the executrix
from office . Ultimately, on 14 February 2024, the Master advised the executrix that she
had failed to satisfactorily perform the duties imposed upon her by the Administration of
Estates Act (the Act)1, as requested by him in two query sheets. Accordingly, he gave
notice in terms of s 54(2) of the Act that he intended, in terms of s 54(1)(b)(v) of the Act,
to remove her as executrix in the estate (the removal notice ), unless she applied to
court within 30 days from the date of notice to restrain him from doing so.2 Hence the
application.
[2] The executrix in her notice of motion, sought an order tha t the Master be
restrained and interdicted from removing her as executrix in the estate. In the
alternative, in the event that he has already elected to remove her from her office, she
1 Act 66 of 1965.
2 The material portion of s 54 read:
‘(1) An executor may at any time be removed from his office -
(a) …
(b) by the Master -
(i) …
(v) if he fails to perform satisfactorily any duty imposed upon him by or under this Act or to
comply with any lawful request of the Master; or
...
(2) Before removing an executor from his office under subparagraph … (v) of paragraph (b) of sub-
section (1), the Master shall forward to him by registered post a notice setting forth the reasons for such
removal, and informing him that he may apply to t he Court within thirty days from the date of such notice
for an order restraining the Master from removing him from his office.’ The executrix has contended that
the removal notice had not been forwarded to her by registered mail and that the notice was, a ccordingly,
of no force or effect. By virtue of the decision to which I have come it is not necessary to consider this
argument.
sought an order that such decision or ruling be set aside. The Master did not enter an
appearance to defend, but Mr Nel and Ms Swart, being the disgruntled heirs, opposed
the application.
Background
[3] During his life the deceased had been married to one S Bell and they had jointly
owned an immovable property in Jeff reys Bay, each ow ning one half share. Ms S Bell
died shortly before the deceased and the applicant was eventually appointed the
execut rix of her estate, too. S he had bequeathed her half share of the property to the
deceased . However, her estate had not been finalised , and letters of executorship had
not been issued to the executrix at the time that the deceased died on 18 April 2018. As
I have said, in his will the deceased appointed the applicant as the executrix of his
estate. He bequeathed one third of his estate in equal shares to two grandchildren born
from his stepson, Phillip John Nel (Phillip Nel) , to be held in trust. They are represented
in these proceedings by the trustees of the mortis causa trust created for them for this
purpose, nam ely, the Bell Family Will Trust (the trust). The deceased bequeathed the
remaining two thirds of his estate equally to his other two stepchildren, Mr Nel and Ms
Swart.
[4] On 27 Sep tember 2018, pursuant to the last will and testament, the Master
issued lett ers of executorship in the estate to the appl icant, but not in respect of the
estate S Bell. These letters of executorship in the estate S Bell were only issued in
2023. I shall revert to this issue. Although she is a qualified , but non -practicing,
attorney the executrix chose to appoint one Van Jaarsveld, of the Fiduciary Institute of
South Africa, as her agent (the first agent) . He passed away in December 2020 after he
had done considerable work on the administration of the estate. He had prepared a
liquidation and distribution account (L & D account ), dated 7 November 2019, which was
presented to the Master in November 2019 and the heirs were updated in t his regard in
December 2019. The 2019 L & D account w as examined by the Master and , on 8
January 2020 , he issued a query sheet (the 2020 query), in which he raised a number
of matters that required further attention, including a directive that the trust h ad to be
created for the benefit of the two grandchildren of the deceased, as provided for in the
will. He also directed the executrix to provide certain supporting documents. As I have
said, the first agent passed away before the estate had been finalis ed and before he
had responded to the Master’s query . Much of the work which he had done had been
recorded and stored on his computer and could not be retrieved , which gave rise to
further delay in the administration of the estate.
[5] In January 2021, the applicant appointed one Van Ryneveld, (the second agent)
to assist her in the administration of the estate. His progress in the administration of the
estate was equally slow, and the heirs became unhappy . On 21 February 2023 Mr Nel,
acting on behalf of the heirs, requested the Master to remove the executrix in terms of
s 54 of the Act. The complaint was forwarded to the applicant for her response and,
after obtaining an extension, she responded on 26 May 2023 and provided 1329 pag es
of supporting documentation which reflected the chronology of the activities of her
agents in their endeavour to bring the estate to finality. The chronology reflects the
frustration that the second agent experienced with the inefficiency of the Master s’ office,
particularly during the period when Covid 19 restrictions were imposed, in respect of a
number of issues that caused delay in the progress of the administration. These
related, amongst others, to the appointment of trustees in the trust, the ap proval of the
sale of the property and the issue of letters of executorship in the estate S Bell.
[6] In the interim , on 18 April 2023, the second agent lodged another L & D account.
The Master examined the 2023 L & D account, and, on 2 May 2023, he issued a fresh
query sheet (the 2023 query) raising similar issues to those in the 2020 query. It is
apparent from the 2023 query that the second L & D account did not address the issues
raised in the 202 0 query and the supporting documentation had not been provided.
[7] On 9 August 2023 the second agent emailed the required response to the query
sheet dated 2 May 2023 and attached thereto an amended L & D account. The Master
was unwilling to accept the amended account because it ha d been forwarded to him by
email. The Master did not examine the account , and no query sheet was issued
pursuant thereto because, so the Master contended, the original had not been lodged.
Accordingly, on 11 September 2023 , the second agent lodged the co rrespondence
previously emailed to the Master in their original form . Again, the Master declined to
issue a query sheet and contended that ‘no original certificate by the executrix’ was
submitted. Nevertheless, the Master examined the amended L & D accou nt.
[8] In the removal notice the Master recorded that the had required proof in the 2020
query of the publication of a notice in terms of s 29(1) of the Act calling upon persons
having claims against the estate to lodge such claims with him.3 In the amen ded L & D
account the Master noted that an advertisement in terms of s 29 had been lodged in the
Business Day and the Government Gazette on 30 June 2023, more than three years
after the dispatch of the 2020 query. He noted further that he had requested vouchers
in respect of certain claims against the estate made by Mr Nel and Phillip Nel and that
an affidavit be provided in respect o f claims made by Mr Nel in respect of expenses
which he had incurred on behalf of the estate. These remained outstanding. These
matters had been addressed in the response of the executrix to the complaints of the
heirs and the request for the removal of the executrix to which I have referred earlier .
The executrix had contended that Mr Nel was retarding progress , and he refuse d to
provide the necessary vouchers and affidavit . He contended that same had been
provided to the first agent in 2019 and the ex ecutrix ought to have them . The Master ,
too, considered that the executrix ought to have been in possession of these vouchers
when the first L & D account was drafted.
[9] Accordingly, in his notice of removal , the Master concluded that the executrix had
clearly failed to comply satisfactorily with the duties imposed upon her by the Act or his
3 Section 29(1) provides: ‘Every executor shall, as soon as may be after letters of executorship have
been granted to him, cause a notice to be published in the Gazette and in one or more newspapers
circulating in the district in which the deceased ordinarily resided at the time of his death and, if at any
time within the period of twelve months immediately preceding the date of his death he so resided in any
other district, also in one or more newspapers circulating in that other district, …, calling upon all persons
having claims against his estate to lodge such claims with the executor within such period (not being less
than thirty days or more than three months) from the date of the latest publication of the notice as may be
specified therein.’
lawful requests. In doing so he relied primarily on the failure to have published the
advertisement required in terms of s 29(1) timeously and her failure to respond t o the
2020 query or to address the issues raised therein whe n the second L & D account was
lodged. He recorded further that certain of his requests, notably the vouchers to which I
have referred, had still not been complied with.
Nature of the applicat ion.
[10] I have set out earlier the relief sought in the notice of motion. Mr Costa , who
appeared on behalf of the executrix, argued that the Master has taken no further steps
to remove the applicant as executrix following the notice of removal and submitted,
accordingly, that there was no need for the alternative relief . He focused the argument
on the interdictory relief. Ms Ellis, on behalf of Mr Nel and Ms Swart, similarly,
approached the matter as an interdict and submitted that the application should be
dismissed as the applicant had failed to demonstrate a clear right to continue a s
executrix.
[11] The approach cannot be sustained. In Oberhols ter4 the Full Court, in Gauteng ,
emphasised that it was wrong to approach the matter as if it were an interdict. Indeed, it
seems to me, that save for exceptional matters where the Master may have
misconstrued the true facts, an executrix would be hard pressed to demonstrate a clear
right. Thus, in Oberhols ter, the court explained that the application was one requiring
the court to decide whether it was ‘undesirable’ for the executor to continue in his
position . I do not think that this categorisation ade quately explains the nature of the
application either.
[12] The provisions of s 54 of the Act were recorded earlier.5 In interpreting the
provisions of the legislation the language used should be considered in the context in
which the relevant provisions appear , with due regard to the apparent purpose to which
4 Oberhols ter NO and Others v Richter [2013] 3 All SA 205 [GNP ].
5 Fn 2
it is directed.6 In addition, all statutory provisions should be interpreted consistently with
the Constitution.7
[13] Section 54(1)(b)(v) confers on the Master the authority to remove the executrix
from office if she fails to pe rform her duties satisfactorily. Once he has taken a decision
in this respect and given notice in terms of s 54(1)(b) , his decision is final , and he is
functus officio8. Accordingly, the M aster has already elected to remove the executrix
from office. The effect of s 54(2) is simply that the Master may not implement his
decision for 30 days , so as to permit the executrix an opportunity to challenge his
decision. However, his decision constit utes administrative action9, as envisaged in the
promotion of Administrative Justice Act, 3 of 2000 (the PAJA) .10 As such, the decision of
the Master is valid and it stands until it is reviewed and set aside.11 It follows that
interdictory relief can onl y be granted if the decision of the Master is first reviewed and
set aside.
[14] Generally, the PAJA is the appropriate route for the review of administrative
action . However, where the legislature has conferred on a court a statutory power of
review of conduct which constitutes administrative action , a party may choose whether
to proceed under the PAJA , or under the special statutory review.12 Section 95 of the Act
provides for such a special statutory review13. Where the statutory provision is silent in
6 Natal Joint Pension Fund v Endumeni Municipality 2012 (4) SA 59 3 (SCA) para 18.
7 Cool Ideas 1186 CC v Hubb ard and Another 2014 (4) SA 474 (CC) para 28.
8 Levinson NO v Master of the High Court and Others (A5032/2019)[2020] ZAGPJHC 254 (16 October
2020) para 28; and Coetze r and Another v De Koc k NNO and Others 1976 (1) SA 351 (O) at 359C -H.
9 Nel and Another NNO v The Master (Absa Bank Ltd and Others Intervening) 2005 (1) SA 276 (SCA)
para 28. (The decision in Nel concern ed a statutory review in terms of s 151 of the Insolvency Act, 24 of
1936 ); and City Capital SA Property Holdings Limited v Chavonnes Badenhorst St Clair Cooper NO 2018
(4) SA 71 para 42 and 43.
10 Material portion of s (1) of the PAJA defines ‘administrative action to mean ‘any decision taken … by
(a) an organ of State, when -
(i) …
(ii) exercising a public power or performing a public function in terms of any legislation ; … which
adversely affects the rights of any person and which has a direct, external legal effect ….’
11 Oudekraal Estates (Pty) Ltd v City of Cape Town and Others 2004 (6) SA 222 (SCA) para 26.
12 Hoexter and Penfold: Administrative Law in South Africa (3rd ed) at 154.
13 Section 95 , as it was at the time , provided: ‘Every appointment by the Master of an executor …, and
every decision, ruling, order, direction … by the Master under this Act shall be subject to appeal to or
review by the court upon motion at the instance of a ny person aggrieved thereby, and the court may on
respect of the grounds of review the grounds set out in the PAJA apply. 14 Thus, it
seems to me that the application referred to in s 54( 2), interpreted in its context,
consistently with s 33 of the Constitution, is simply a review as provided for in s 95 of
the Act. Accordingly, I intend to approach the matter, rather as a review of the Master’s
decision .
[15] A special statutory review of the kind envisaged in s 95 has been categorised as
the third kind of review identified by Innes CJ in Johannesburg Consolidated Investment
Co.,15 being a proceeding in which the court may enter upon and decide the matter de
novo, exercising not only the powers of a court of review in a legal sense but also
having the functions of a court of appeal and enjoying the additional privilege of being
able, after setting aside the decision arrived at by the decision maker, to deal with the
whole matter upon fresh evidence as if it were the decision maker of first instance.16
The precise extent of any ‘statutory review type power’ must always depend on the
particular statutory provision concerned and the nature and extent of the functio ns
entrusted to the person or the body making the decision under review.17 The exercise
of the power afforded the Master in s 54(1)(b)(v) of the Act is governed by expressly
identified objective criteria. A decision to remove an executor in terms of the section
requires a finding by the Master (i) that the executrix has failed to perform satisfactorily
any duty imposed upon her by or under the Act , or to comply with any lawful request of
the Master , and (ii) assuming an affirmative finding on (i) , a decision whether the
removal is an appropriate and proportionate consequence in the circumstances.18 In
respect of the second requirement B inns-Ward J noted in Van Zyl that ‘the Master (is)
any such appeal or review confirm, set aside or vary the appointment, decision, ruling, order, direction …
as the case may be.’
14 Fuel Retailers Association of Southern Africa v Director General: Environme ntal Management,
Department of Agriculture, Conservation and Environment, Mpumalanga Province, and Others 2007(6)
SA 4 (CC) at para 37.
15 Johannesburg Consolidated Investment Co. v Johannesburg Town Council 1903 TS 111 .
16 Cooper NO v South African Mutual Life Assurance Society and Others [2000] ZASCA 64 para 11; and
Nel para 22.
17 Nel para 23.
18 Master of the High Court Western Cape Division, Cape Town v Van Zyl [2019] 2 All SA 442 (WCC) para
12. (Van Zyl concerned the remover of a liquidator in terms of s 379(1) and (b) of the 1973 Companies
Act.) See also Meyerowitz on Administration of Estates and their taxation (2023 ed) at 125 , in respect of
executors.
obliged to acknowledge and respect the recognition by the courts that the removal of a
liquidator is an “extreme step”19, and must weigh why, in the context, the other (less
extreme) remedies provided in the Act to deal with shortcomings in the liquidator’s
conduct would not suffice.’ These considerations find equal application to the removal
of a testamentary executrix.20
Discussion
[16] Much was ma de in the extensive papers about the overall delay in the finalisation
of the estate. It is indisputable t hat the effect of the Covid 19 pandemic and the
consequent lockdown in South Africa in 2020 hampered the activities of all government
departments, including the office of the Master. The response of the executrix to the
complaint by Mr Nel demonstrates ongoi ng endeavours by the agents of the executrix in
obtaining necessary information and actions from the office of the Master, in particular
relating to the appointment of trustees for the trust.
[17] As I have said , one half of the property jointly owned by the deceased and estate
S Bell remained registered in the name of S Bell and had first to be transferred to the
estate before it could be dealt with in the estate. The letters of executorship in the
estate S Bell were only issued in 2023 and the Master, in h is notice of removal ,
acknowledged this failure. This inevitably would have delayed the finalisation of the
deceased estate. Notwithstanding these explanations, the undue delay in the
administration of the estate is indisputable. For example, no expla nation at all has been
provided for the first agent’s failure to have perused the establishment of the trust
before the first L & D account was prepared. Numerous acrimonious disputes that
further delayed progress between the disgruntled heirs and the exe cutrix in respect of
the sale and transfer of the property. Accusations and counter accusations end ured for
19 See Standard Bank of South Africa v The Master of the High Court and Others 2010 (4) SA 405 (SCA)
at para 135; Ma-Africa Groep Belange (Pty) Ltd and Another v Millman and Powell NNO and Anot her
1997 (1) SA 547 (C) at 666.
20 Gowar and Another v Gowar and Others 2016 (5) SA 225 (SCA) at para 30, in the context of a removal
of a trustee; and Volkwyn NO v Clark & Demant 1946 WLD 456 at 464.
many months. However, by virtue of the conclusion to which I have come it is not
necessary to enter into these disputes.
[18] Suffice it to say that delay is not the only complaint raised by the Master. I have
referred earlier to the grounds set out in the removal notice issued by the Master. In the
2020 query sheet he requested proof of the s 29 notice. The request was repeated in
the 2023 query s heet and the s 29 notice was eventually published on 30 June 2023.
Section 29 requires the notice be published ‘as soon as may be after letter s of
executorship h ave been granted. ’21 It is one of the first steps which an executor is
required to take in the administration of the estate and the notice calls upon all persons
having claims against the estate to lodge such claims with the executor within a period
specified in the notice. In terms of s 35 of the Act the executor is required to submit an
L & D account to the Master ‘as soon as may be’ after the last day specified in s 29(1),
but within six months after the letters of executorship have been granted to him.22 An L
& D accoun t cannot be prepared without first determining the liabilities of the estate. As
adumbrated earlier the first L & D account was submitted on 7 November 2019, more
than a year after the letters of executorship had been granted to the executrix.
Thereafter , the 2020 query sheet was issued and more than three years passed from
the date of the query sheet to the publication of the advertisement.
[19] The executrix ha s tendered no explanation for the delay in publishing the
advertisement which occurred under the first agent , nor has any explanation been
offered for the further extensive delay under the second agent in this regard.
[20] Mr Costa contended that it was not open to the Master to rely on these fail ures
because, on his own account, the advertisement had already been placed when he
issued the removal notice. I do not think that the submission is sound in respect of the
first step on the enquiry . As I have demonstrated above there has been a gross
dereliction of duty in respect of s 29 of the Act and I think that the Master is entitled to
21 The provisions of s 29 are set out in fn 3.
22 Unless the Master has granted a special extension in terms of s 35(1)(b).
expect of the executrix to perform her functions in terms of the Act. He should not be
criticised for removing a n executrix if he is satisfied that she has failed to perform her
functions satisfactorily, unless he can be reasonably confident that she will live up to
those requirements in the future.
[21] That brings me to the second step of the enquiry, whether the removal of the
executrix is an appropriate and proportion al consequence in the circumstances. Many
of the issues that lay at the heart of the delays had been resolved prior to the notice of
removal. The trust had been established, the trustees appointed, the disputes relati ng
to the sale and transfer of the immovable property had been resolved and the Master
had approved the transfer of the property in terms of s 42(2) of the Act.23 At the time
that the application was argued the property had already been transferred. An
amended L & D account had been lodged in August 2023 and the only issues
outstanding in order to finalise the estate, as recorded in the notice of removal, were
certain vouchers in respect of personal loan s in favour of Mr Nel and Phillip Nel and an
investmen t, and an affidavit in respect of expenses paid by Mr Nel on behalf of the
estate. These, the Master considered, ought to have been in possession of the
executrix before the first L & D account had been prepared. I accept, for purposes of
this judgment t hat the Master is correct in this contention, but it is not disputed that Mr
Nel is in a position to re -submit these vouchers .
[22] The question which arises is whether , in these circumstances, the removal of the
executrix is an appropriate and proportionate c onsequence of her failure . In
Pharmaceutical Manufacturers24 Chaskalson P held that the Constitution required that
the exercise of public power must be objectively rational. He said:
[85] It is a requirement of the rule of law that the exercise of public power by
the Executive and other functionaries should not be arbitrary. Decisions must be
23 Section 42(2) provides: ‘ An executor who desires to effect transfer of any immovable property in pursuance of a
sale shall lodge with the registration officer, in addition to any such other deed or document, a certificate by the
Master that no objection to such transfer exists .’
24 Pharmaceutical Manufacturers Association of SA and Another: In re Ex Parte President of the Republic
of So uth Africa and Others 2000 (2) SA 674 (CC) para s 85-86.
rationally related to the purpose for which the power was given, otherwise they
are in effect arbitrary and inconsistent with this requirement. It follows that in
order to pass constitutional scrutiny the exercise of public power by the Executive
and other functionaries must, at least, comply with this requirement. If it does
not, it falls short of the standards demanded by our Constitution for such action.
[86] The question whether a decision is rationally related to the purpose for
which the power was given calls for an objective enquiry. …
[23] The powers given to the Master in terms of the Act are solely for the protection of
the interests of cred itors, heirs, legatees, and all other persons having a claim upon an
estate.25 Thus, generally an executrix should not be removed from office unless her
continuance in office will prevent the estate being properly administered or will be
detrimental to th e welfare of beneficiaries.26 There is no case made out for the
dishonesty of the executrix in the administration of the estate and the complaint centres
essentially on the inordinate delay which has occurred. I have no doubt that her
conduct has fallen short of the ideal , which justified the Master’s conclusion that she
had not performed her function satisfactorily. However, the removal of a testamentary
executrix, who the deceased had selected to carry out his wishes, constitutes an
extreme step. In Volkwyn27 the court noted:
‘Even if the …administrator had acted incorrectly in his duties, and has not
observed the strict requirements of the law, something more is required
before his removal is warranted. Both the statute and the case cited indicate
that the sufficiency of the cause for removal is to be tested by a consideration
of the interests of the estate … .’
[24] Once an estate has been administered for a substantial period there may almost
always be criticism of the conduct of the executri x, in the sense that there would be
25 Wessels v The Master of the High Court (1892) 9 SC 18.
26 Gowar and Another para 28.
27 At p. 464.
things that could have been done better or things that could have been done earlier. It
is easy for lawyers, who have not been involved in the administration of the particular
estate, to say, with the benefit and wisdom of hindsight, how they could have done
better . But the Master has to bear in mind that in almost any case where he elects to
remove an executor from office, and replaces him with another, there will be undesirable
consequences in terms of costs and in t erms of delay.28 In this case, as I have said, the
estate is, for practical purposes, finalised. What remains outstanding is in the
possession and control of Mr Nel. It may be that he had previously provided these
vouchers to the first agent and the exe cutrix ought to have been in possession of the
vouchers at the time when the first L & D account was rendered. That does not detract
from the fact that the estate is all but finalised and the removal of the executrix and the
appointment of a new executor would inevitably give rise to further delays. A new
executor, too, would be required t o assess the existing amended L & D account and all
the supporting documentation to satisfy himself as to the correctness thereof in order to
sign an executor’s certificate.29 He, too, would be required to obtain new copies of the
vouchers from Mr Nel, wh ich he has been reluctant to give. Nothing could be gained by
the removal of the executrix at this stage of proceedings and the papers do not
demonstrate any risk to the heirs or legatees going forward.
[25] To the extent that reliance has been placed on hist oric delays , including the s 29
advertisement, it is significant that the Master has not sought to compel the executrix to
comply with any provision of the Act or reasonable requests , which he could have done
in terms of the powers vested in him under s 36 of the Act. For these reasons the
decision of the Master to remove the executrix from office is not rationally connected to
the purpose of the power vested in him in s 54 of the Act, and it was not, at the time that
it was taken an appropriate consequence of her failure.
[26] The following order is made:
28 AMP Music Box Enterprises Limited v Hoffman [2003] 1 BCLC 319 at para 27, quoted with approval in
Van Zyl at p. 452 -453.
29 Regulation 5(1)(i).
1. The decision of the Master in terms of s 54(1)(b)(v) to remove the applicant as
executrix in the Estate Late Alexander Morrison Bell (2899/2018) is reviewed and
set aside.
2. The first respondent is restrained from removing the applicant as executrix in the
estate.
3. The second and third respondents are ordered to pay the costs of the
application , jointly and severally, including the costs of two counsel on scale B.
J W EKSTEEN
JUDG E OF THE HIGH COURT
Appearances:
For App licant : Adv M Costa & Adv Z Minty
Instructed by: Reenen van Reenen Inc
c/o Goldberg & De Villiers Inc
GQEBERHA
For 2nd & 3rd
Respondents: Adv L Ellis
Instructed by: Muller & Co Attorneys
c/o AUKETT ATTORNEYS
GQEBERHA
Date Heard: 31 October 2024
Date Delivered: 4 February 2025