1. The Applicant seeks to declare void or invalid ab initio two settlement agreements and related transactions, entered into in terms of the Restitution of Land Rights Act 22 of 1994 – the BCR Settlement and the RSE Settlement.
2. The Fourth to Sixth Respondents are parties to (or affected by) the second of these transactions: namely, the RSE Settlement Agreement (and related transactions), signed on 26 April 2009. These Heads of Argument concern only the RSE Settlement Agreement and do not attempt to deal with the BCR Settlement (except insofar as to distinguish the two transactions where necessary).
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Dube HOA 050613 (final)
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