IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA HELD AT BRAAMFONTEIN
Case Number: CCT 124/2015
In the application for admission as amicus curiae of:
PEOPLE AGAINST SUFFERING, OPPRESSION AND POVERTY Applicant
In the matter between:
THE MINISTER OF HOME AFFAIRS Applicant
and
ABDUL RAHIM First Respondent
HOSSAIN KAMAL Second Respondent
ZAKIR HOSSAIN Third Respondent
HARUN MOHAMMED Fourth Respondent
MOHAMMED SALA UDDIN Fifth Respondent
ABDUL SHAMOL Sixth Respondent
MAHBUB ALOM Seventh Respondent
TOYOBUR RAHMAN Eighth Respondent
SUMAN CHUDHURY Ninth Respondent
MUSTAFI GURRAMAN Tenth Respondent
EUNICE HAYFORD Eleventh Respondent
ZAIUR RAHMAN Twelfth Respondent
MD ALAP Thirteenth Respondent
NORUL ALOM Fourteenth Respondent
MAHE MINTU Fifteenth Respondent
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NOTICE OF APPLICATION FOR ADMISSION AS AN AMICUS CURIAE IN TERMS OF RULE 10(4)
KINDLY TAKE NOTICE THAT People Against Suffering, Oppression and Poverty (“Applicant”) intends to apply to this Court for an order in the following terms:
1. Condoning the late filing of this Application.
2. Admitting the Applicant as an amicus curiae in the Main Application.
3. Granting the Applicant––
3.1. the right to lodge written argument in the Main Application; and
3.2. the right to present oral argument at the hearing of the Main Application.
Provided that such argument does not repeat matters set forth in the arguments of the parties and raises new contentions which may be useful to the Court.
4. Further and / or alternative relief.
TAKE NOTICE FURTHER that the attached affidavit of BERNARD DIPO TOYAMBI and the annexures thereto will be used in support of this application.
TAKE NOTICE FURTHER that the Applicant has appointed the address of its attorneys as set out below at which it will accept notice and service of all process in these proceedings.
DATED AT JOHANNESBURG ON THIS THE 11th DAY OF NOVEMBER 2015.
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LEGAL RESOURCES CENTRE Per: Michael Power Applicant’s Attorneys 15th Floor, Bram Fisher Towers 20 Albert Street Marshalltown JOHANNESBURG 2000 Tel: 011 836 9831 Fax: 011 836 8680 Email: [email protected] / [email protected] / [email protected] Ref: 11102915J / MJ Power
TO: THE REGISTRAR OF THE ABOVE HONOURABLE COURT
AND TO: THE STATE ATTORNEY
Attorney for the Applicant in the Main Application 29 Western Road
Central
PORT ELIZABETH Tel: 041 585 7921
E-mail: [email protected] C/O THE STATE ATTORNEY 10th Floor, North State Building
95 Albertina Sisulu Street, Cnr Kruis Street JOHANNESBURG
Ref: MR V DHULAM Tel: 011 330 7621
AND TO: McWILLIAMS & ELLIOT INC.
Attorneys for the Respondents in the Main Application E-mail: [email protected]
C/O MOODIE & ROBERTSON ATTORNEYS 4th Floor
222 Smit Street Braamfontein JOHANNESBURG Tel: 011 403 5171 Fax: 011 403 1946
Email: [email protected] Ref C Walters/nr/M305719
