IN THE CONSTITUTIONAL COURT OF

Case No: 32/18 In the application of: THE UN SPECIAL RAPPORTEUR ON THE RIGHTS TO FREEDOM OF PEACEFUL Applicant for leave to ASSEMBLY AND OF ASSOCIATION intervene as amicus curiae

In the matter between:

PHUMEZA MLUNGWANA First Applicant

XOLISWA MBADISA Second Applicant

LUVO MANKQO Third Applicant

NOMHLE MACI Fourth Applicant

ZINGISA MRWEBI Fifth Applicant

MLONDOLOZI SINUKU Sixth Applicant

VUYOLWETHU SINUKU Seventh Applicant

EZETHU SEBEZO Eighth Applicant

NOLULAMA JARA Ninth Applicant

ABDURRAZACK ACHMAT Tenth Applicant and

THE STATE First Respondent

THE MINISTER OF POLICE Second Respondent

NOTICE OF APPLICATION: RULE 10

PLEASE TAKE NOTICE that the applicant for leave to intervene intends to apply to this Court, on a dated to be determined by the Registrar, for an order in the following terms –

1. The United Nations Special Rapporteur on the rights to freedom of peaceful

assembly and of association is admitted to these proceedings as amicus curiae.

2. The amicus curiae is granted –

2.1. the right to lodge written argument; and

2.2. the right to present oral argument at the hearing of this matter.

provided that such argument does not repeat matter set forth in the arguments of

the other parties, and raises new contentions which may be useful to the court.

3. Further and/or alternative relief.

TAKE NOTICE FURTHER that the affidavit of THULANI NKOSI, together with the annexures thereto, will be used in support of this application.

TAKE NOTICE FURTHER that the applicant for leave to intervene has appointed

THE SERI LAW CLINIC as his attorneys of record, at the address set out below, where he will accept service of all further notices, documents and other process in connection with these proceedings.

DATED AND SIGNED AT ON THIS THE 11th DAY OF JUNE

2018

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SERI LAW CLINIC Applicants’ Attorneys 6th Floor, Aspern House 54 De Korte Street Braamfontein, 2001 Tel: 011 356 5860 Fax: 011 339 5950 E-mail: [email protected] REF: Nkosi/Mametja

TO : The Registrar Constitutional Court

AND TO : Legal Resources Centre Attorneys for the Applicants 3rd Floor, Greenmarket Place Tel: 021 481 3000 Email: [email protected] Ref: S KAHANOVITZ C/O Legal Resources Centre, Johannesburg 16th Floor, Bram Fischer House 20 Marshalltown Street JOHANNESBURG Ref: (Ms. C Du Toit) Email: [email protected]

AND TO : The State Attorney Attorneys for the Respondent 22 Long Street Cape Town Email: [email protected] C/O THE STATE ATTORNEY, JOHANNESBURG 10th Floor, North State Building 95 Albertina Sisulu Street JOHANNESBURG Ref: (Vijay Dhulam) Email: [email protected]

AND TO : EQUAL EDUCATION LAW CENTRE Attorneys for First Amicus 8 Mzala Street Khayelitsha Cape Town Email: [email protected] C/O CENTRE FOR APPLIED LEGAL STUDIES 1ST Floor, DJ du Plessis Building West Campus University of Witwatersrand Braamfontein JOHANNESBURG Ref: (Lisa Chamberlain) Email: [email protected]