ATTORNEY-GENERAL REF NO: JCT 94/0001 CONST. COURT CASE NO 3/94
IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA
In the matter of:
MAKWANYANE, THEMBA MCHUNU, MVUSO . ~
CONSTITUTIICNAI. COURT
PRIVATE BAG/PRIVAATSAK X32
1995 -02- 1 3 «-
BRAAMFONTEiN 2017
KOMSTITUSEOW5LE SHIOF
APPLICANTS
and
THE STATE RESPONDENT
THE RESPONDENT'S REPLY TO THE HEADS OF ARGUMENT OF
1) THE GOVERNMENT OF SOUTH AFRICA
2) THE BLACK ADVOCATES FORUM
A AD THE GOVERNMENT OF SOUTH AFRICA
1 If the Court regards the Government as an amicus curiae, the Respondent does not agree to oral argument on its behalf in terms of the President's directive, as its Heads contain no new arguments.
2 The issues raised by the Government in its Heads have in the main already been dealt with in the Respondent's Heads.
B AD BLACK ADVOCATES FORUM
3 As the Heads of this amicus curiae do not contain new arguments, the Respondent does not agree to oral argument on its behalf.
4 The Respondent views it as unnecessary to reply to these Heads.
C** Attached hereto is Part One of J R Lund's article (Vl-27), which was erroneously omitted from Volume 1 of the Respondent's List of Authorities.
I
DATED AT JOHANNESBURG ON THIS 13th DAY OF FEBRUARY 1995.
K P C O VON LIERES UND WILKAU T P McNALLY SC
J S M HENNING SC
COUNSEL FOR RESPONDENTS
TO: The Registrar
Constitutional Court Private Bag X32
BRAAMFONTEIN 2017
25 copies.
AND TO: The Director
Legal Resources Centre 8th Floor
Elizabeth House Pritchard Street JOHANNESBURG 2001
AND TO: Adv E Zar SC
Counsel for I Glauber Group 725
7th Floor, Innes Chambers Pritchard Street
JOHANNESBURG 2001
AND TO: A Motala and S Ebrahim
c/o Lawyers for Human Rights 6th Floor
North State Building
cnr Market & Kruis Streets JOHANNESBURG
2001
AND TO: Black Advocates Forum c/o Nat A Victor
7th Floor Khotso House
62 Marshall Street JOHANNESBURG
2001
AND TO: The State Attorney 10th Floor
North State Building 95 Market Street JOHANNESBURG 2001