IN THE SUPREME COURT OF APPEAL

SCA Case No. A.815/2011

In the matter between:

JULIUS SELLO MALEMA - First Appellant

AFRICAN NATIONAL CONGRESS - Second Appellant and

AFRIFORUM - First Respondent

TAU-SAU - Second Respondent and

VERENIGING VAN REGSLUI VIR AFRIKAANS - First Amicus Curiae

COUNCIL FOR THE ADVANCEMENT OF THE SOUTH AFRICAN CONSTITUTION -Second Amicus Curiae

FREEDOM OF EXPRESSION INSTITUTE and SECTION 16 NPO - Third Amicus Curiae

SUBMISSIONS ON BEHALF OF THE COUNCIL FOR THE ADVANCEMENT OF THE SOUTH AFRICAN CONSTITUTION

I: INTRODUCTION

1. CASAC is a non-governmental organization which advances the South African Constitution as a platform for democratic politics and the transformation of society based on the core principles of the Constitution. CASAC has intervened in this appeal as amicus curiae because of its concerns as to the consequences of the High Court judgment.

2. CASAC submits that:

2.1. In order to determine whether there has been a breach of sec 10 of the Equality Act, a court must determine what a reasonable person would or could have considered the clear intent of the speaker to be.

2.2. A reasonable person would have regard to the context in which the speaker spoke, in order to attribute an intention to the speaker.

2.3. Section 10 therefore requires the court to consider the context of the speech. This includes matters such as (1) the nature of the event; (2) the nature of the audience; (2) the meaning of the words for that audience; (3) the manner of the speech; and (4) the identity of the speaker.

2.4. This means that the High Court was required to examine the evidence with regard to the context of each one of the occasions on which the song was sung by Mr Malema, in order to determine in each case whether the complainants produced sufficient evidence to justify a finding of a breach of sec 10.

2.5. Because the High Court did not appreciate this and did not undertake this exercise, it erred in its application of the facts of the case to sec 10.

2.6. CASAC does not seek to make submissions on the detailed facts of each of the incidents in order to analyse whether this burden was discharged in each case. That is the province of the parties. CASAC submits however that a "broad-brush" and generalised approach such as was adopted by the High Court is impermissible.

2.7. CASAC submits further that the blanket ban on the singing of the song was without any justification at all.

2.8. When the High Court found that the speech in question was directed at a "minority" group, the Afrikaner community, it erred in not having regard to the fact that "minority" in this context is not simply a matter of numbers. It is a concept which  embraces marginalisation and vulnerability.

2.9. CASAC submits further that in undertaking this analysis, sec 10 must be interpreted in a manner which promotes the spirit, purport and objects of the Bill of Rights, and in particular the freedom of speech guaranteed by sec 16 of the Constitution.

II: THE JUDGMENT

3. Lamont J found that the singing of the song containing the words "awudubul' ibhunu"and "dubula amabhunu baya raypha" constituted hate speech under sec 10 of the Act. He interdicted the First and Second Appellants "from singing the song... at any public or private meeting held or conducted by them".

4. In coming to his conclusion, Lamont J found:

4.1. The "target group" of the song were "the Afrikaners". They must be treated as the audience even though they were not physically present.1 They were a minority that were regarded as particularly vulnerable. The Court had a "clear duty" to come to their assistance.2  .

4.2. The words used had an effect both on the target group and on the group that takes part in the singing. In particular, words could motivate one group to commit acts of violence against another.3

4.3. While it may have been acceptable to sing the song during apartheid, it was now no longer acceptable to sing the song because the apartheid regime - whose destruction the song was calling for - "was destroyed at the time of the transformation of the country into a democracy".4

4.4. It had been contended that the song was also sung as part of the heritage of the struggle against apartheid. However, "[m]embers of society are enjoined to embrace all citizens as their brothers .... the Equality Act allows no justification on the basis of fairness for historic practices which are hurtful to the target group but loved by the other group."5

III: INTERPRETING SECTION 10 OF THE EQUALITY ACT

5. Section 39(2) of the Constitution requires that sec 10 be interpreted in a manner which promotes the spirit, purport and objects of the Bill of Rights. This includes the freedom of speech guaranteed by sec 16 of the Constitution.

6. As the Constitutional Court has noted, "words can never attain precision, since they are as intrinsically dynamic as they are inexact."6  The Act is to be given that interpretation which is not unreasonably strained, and which best gives effect to the spirit, purport and objects of the Bill of Fights.

7. As appears from the Preamble, the primary purpose of the Act is to give effect to the constitutional right to equality. The Act also has as its purpose to give effect to"the prohibition of advocacy of hatred, based on race, ethnicity, gender or religion, that constitutes incitement to cause harm as contemplated in section 16(2)(c) of the Constitution and section 12 of this Act".7

8. The link between the Act and the constitutional right to freedom of expression, and the constitutional limits on that right, is therefore explicit.

9. Section 10 provides:

Subject to the proviso in section 12, no person may publish, propagate, advocate or  communicate words based on one or more of the prohibited grounds, against any person, that could reasonably be construed to demonstrate a clear intention to -

(a) be hurtful;

(b) be harmful or to incite harm;

(c) promote or propagate hatred.

10. Section 12 of the Act is given a doubly pivotal role in dealing with hate speech. Section 2(b)(v) states that the object of the Act is to prohibit prohibition of advocacy of hatred as contemplated in sec 12. And in addition, the prohibition in sec 10(1) is"Subject to the proviso in section 12".8

11. The proviso is this:

Provided that bona fide engagement in artistic creativity, academic and scientific enquiry, fair and accurate reporting in the public interest or publication of any information, advertisement or notice in accordance with section 16 of the Constitution, is not precluded by this section.

12. The Act thus also foregrounds sec 16 of the Constitution. We submit that the structure of the Act and of sec 10 demonstrate that sec 10 is not intended to trench upon the free speech rights contained in sec 16 of the Constitution.

13. It is also important, for the submissions which follow, to note that sec 4(2)(a) requires that when applying the Act, cognisance should be taken of the existence of systematic discrimination and inequalities particularly in respect of race, gender and disability brought about as a result of colonialism and apartheid.

IV: DETERMINING ATTRIBUTED INTENTION

(i) The fundamental importance of context

14. The core element of the definition is whether the words used "could reasonably be construed to demonstrate a clear intention" on the part of the speaker to achieve one of the prohibited outcomes.

15. The intention is not determined subjectively, by reference to the actual intention of the speaker. The test is objective: how the words could reasonably be construed in determining the speaker's intention. Put differently, the enquiry is how a reasonable person would or construe the speaker's intention. We refer to this as the attributed intention.

16. The attributed intention must be a "clear" intention - not an ambivalent or ambiguous intention.

17. The attributed intention can only be determined by reference to the context:

It may be accepted that the reasonable person must be contextualized and that one is not concerned with a purely abstract exercise. One must have regard to the nature of the audience. In this case the main target was the school children at the particular school, but it also included at least teachers.9

18. The function of context as an essential determinant is demonstrated by positing the singing of the present song in two different contexts:

18.1. If the song is sung in a choir competition, attended by enthusiasts for choral singing, a reasonable person could not conclude that the clear intention of the singers was to be hurtful, to be harmful, to incite harm, or to promote or propagate hatred. A reasonable person would conclude that the clear intention was to entertain and to demonstrate the singing prowess of the choir.

18.2. If the song is sung at the gate of a farm, in the presence of a group of people who have unlawfully occupied the farm, and in the context of an angry dispute between them and the farm-owner, a reasonable person could conclude that the singer had the clear intention to achieve one of the prohibited outcomes.

19. The forum can transform neutral speech into hate speech. In Bropho v Human Rights & Equal Opportunity Commissioner,10 French J said:

The publication of a genuine scientific paper on the topic of genetic differences  between particular human populations might, for one reason or another, be insulting or offensive to a group of people. Its discussion at a scientific conference would no doubt be reasonable. Its presentation to a meeting convened by a racist organisation and its use to support a view that a particular group of persons is morally or otherwise ‘inferior' to another by reason of their race or ethnicity, may not be a thing reasonably done in relation to par (b) of s 18D [of the Race Discrimination Act].

20. The relevant elements of the context include matters such as the following:

20.1. The nature of the event at which the song was sung, as demonstrated by the two hypothetical examples we have given.

20.2. The nature of the audience: that would determine the likely intention of the singer (because no sensible person would sing a song with the intention of stirring up the audience at a choral contest to hatred); and it would determine the meaning which the particular audience would be likely to attribute to it.

20.3. The tone and manner of the singing would influence the intention which a reasonable person would attribute to the singer.

21. As has frequently been said, "In law context is everything."11  Even if it might be said  that the statement is somewhat hyperbolic, it is anything but hyperbolic where the aim is to attribute a clear intention to a speaker or singer. In that situation, context is indeed everything.

22. This is a matter on which the Complainants submitted only limited evidence.

The evidence did not fully canvass the nature of the events in question, the nature of the audience, or the manner in which the song was sung.

23. We submit that it is not adequate simply to conclude, as the High Court did, that the words used have an effect both on the target group and on the group that takes part in the singing, and that the audience is to be taken as "the whole public".12  This is, with respect, altogether too simple and sweeping.

24. Evidence of context is needed to show the likely effect - and to show that it could reasonably be concluded that this was the clear intention of the singer. The High Court found that words could motivate one group to commit acts of violence against another. That is indeed so. But whether that was the (attributed) clear intention of the singer depends on the context.

25. We submit that it is vital to appreciate the different between audience and "target" group with regard to the different forms of prohibited speech:

25.1. Meaning and intention in regard to incitement or propagation of hatred (sec 10(b) and (c) of the Act) are to be construed from the perspective of the audience that is allegedly being encouraged to hate or to harm. The concern is the possibility that the audience will adopt a hateful attitude toward the target group or will be incited to harm. As a result, the reasonable person should be contextualised as a member of this audience, in order to determine whether the speech has this meaning and attributed intention.

25.2. By contrast, in the case of hurtful speech (sec 10(a)), the potential harm in lies in how the words are interpreted by the "target" of the speech. This makes it appropriate to conceive of the reasonable person as a member of the "target" group.

26. We do not intend to make submissions as to whether it could reasonably be concluded that Mr Malema had the prohibited intention in each instance. We submit however that an examination of the context is required in each instance, in order to be able to make a finding in that regard.

(ii) Attributed intention and the ambiguity of meaning

27. The intention behind the singing of the song "Dubul'ibhunu" is fundamentally ambiguous in two respects. Each requires consideration of the context in order to be able to attribute an intention to the singer.

28. First: If particular words of a song have more than one meaning, as in this case, the context is critical. Different audiences will give the words different meanings. If the singer knows the audience, it is reasonable to assume that he is singing in the "language" which he expects and intends them to understand - that is, he is using the words in order to give them the meaning which the audience will attribute to them. In order reasonably to attribute a clear intention to the singer, one therefore needs to examine the context. The words will have different meanings, and a singer is likely to have different intentions in different contexts.

29. We submit that this is critical to this case. If the attributed (objective) intention of Mr Malema was to use "ibhunu" to mean "the system" or "the regime", and not Afrikaners, then it will follow that the prohibited intentions are not applicable as far as that audience is concerned. A reasonable person would consider the context, and in particular the audience and Mr Malema's knowledge of it, in order to attribute an intention to him.

30. Second: The song as a whole may have various intentions. It may be intended literally - as a call to arms; or metaphorically - as a call to renew the collective effort to achieve freedom and wipe out inequality; or as a recollection of the past (a call to memory).

31. Again, one cannot attribute a clear intention to the singer without knowing the context - in particular, the nature of the event, the nature of the audience, and the singer's knowledge of those matters. There appears to be very limited evidence in that regard. This was not addressed by the High Court.

32. Blood-curdling words are sung in many "patriotic" anthems or popular songs without it being reasonable to attribute violent intent to the singer. An example is the French national anthem, "La Marseillaise". It contains the refrain:

To arms citizens 
Form your battalions 
March, march
Let impure blood
Water our furrows.

33. If this were sung at the inauguration of the President of France, no one would attribute a violent intention to the singer. But if it were sung to an angry and armed xenophobic mob, at the entrance to an area occupied by immigrants, it would have a very sinister meaning and intent.

34. Words, gestures or symbols will often have very different associations or meanings for different sections of society. The judgments of the European Court of Human Rights in Vajnai v Hungary13 and Fratanoló v Hungary14 make this point. The applicants were left-wing politicians who were found guilty of the offence of wearing or displaying the "red star", a symbol associated with the Soviet Union. The offence prohibited all displays of the red star or other totalitarian symbols, irrespective of the context. Both applicants claimed that their convictions violated their right to freedom of expression under art 10 of the European Convention on Human Rights. In Vajnai, the Court noted that the red star has very different associations for different sections of Hungarian society: for some it is a hated symbol of Soviet occupation and totalitarianism, while for others it is a symbol of social justice and worker solidarity.15  As a result, it stressed that states should exercise the "utmost care" when imposing restrictions on speech that may have multiple meanings, particularly in the political context:

 [W]hen freedom of expression is exercised as political speech - as in the present case - limitations are justified only in so far as there exists a clear, pressing and specific social need. Consequently, utmost care must be observed in applying any restrictions, especially when the case involves symbols which have  multiple  meanings. In such situations, the Court perceives a risk that a blanket ban on such symbols may also restrict their use in contexts in which no restriction would be justified.16

35. The Court suggested that restrictions on the display of the red star and other totalitarian symbols would only be permissible where this amounts to the propagation of  totalitarian  ideology. The offence was overbroad and potentially restricted legitimate forms of expression, as it applied to any display of these symbols,independent of the context. This was demonstrated on the facts, as the Court found that both politicians were members of left- leaning political parties with no totalitarian ambitions, and they displayed the red star as a form of political expression that did not amount to the propagation of totalitarian ideology.17

36. In Vajnai, the Court emphasised that public feeling alone cannot justify a blanket ban on forms of expression that have multiple, potentially legitimate meanings:

The Court is of course aware that the systematic terror applied to consolidate Communist rule in several countries, including Hungary, remains a serious scar in the mind and heart of Europe. It accepts that the display of a symbol which was ubiquitous during the reign of those regimes may create  uneasiness amongst past victims and their relatives, who may rightly find  such displays disrespectful. It nevertheless considers that such sentiments, however understandable, cannot alone set the limits of freedom of expression. Given the well- known assurances which the Republic of Hungary provided legally, morally and materially to the victims of Communism, such emotions cannot be regarded as rational fears. In the Court's view, a legal system which applies restrictions on human rights in order to satisfy the dictates of public feeling - real or imaginary - cannot be regarded as meeting the pressing social needs recognised in a democratic society, since that society must remain reasonable in its judgement. To hold otherwise would mean that freedom of speech and opinion is subjected to the heckler's veto.18

(iii) Attributed intention and the meaning of history and memory

37. One of the difficulties which faced the High Court was the fact that the song has a significance of its own, beyond the words which are used. It is part of the history of the struggle for democracy, and part of that struggle itself. Memory is also part of building a new society. It would be incongruous and inconsistent with the spirit of the Constitution to "ban" part of our memory of the struggle for democracy, or to "ban" part of that struggle from memory or recall. Yet that is what a blanket ban on the singing of the song would purport or attempt to do.

38. The importance of historical representation has been demonstrated in India, where the courts have repeatedly blocked attempts to use hate speech and censorship laws to suppress the depiction of India's painful history of religious conflict.19 The Delhi High Court summed up the reasoning behind these decisions as follows:

The scenes and visuals ... are in one sense a recalling of the memory of an historical event. The recall may be imperfect. It may contradict the collective memory of that historical event. It may revive tensions over the events being recalled. Yet, that by itself does not invite censorial intervention to obliterate the scenes of recall. 20

39. It may be that a full consideration of the context would lead to the conclusion that the prohibited intention can justifiably be attributed to Mr Malema on one or more of the occasions in question. However, that cannot conceivably justify banning the singing of the song anywhere and on any occasion. Yet that is what the High Court did, even though the complainants did not ask it to do so.

(iv) Attributed intention and the struggle for equality

40. Ours is a transformative Constitution. Chaskalson P expressed this as follows in the Soobramoney case

We live in a society in which there are great disparities in wealth. Millions of people are living in deplorable conditions and in great poverty. There is a high level of unemployment, inadequate social security, and many do not have access to clean water or adequate health services. These conditions already existed when the Constitution was adopted and a commitment to address them, and to transform our society into one in which there will be human dignity, freedom and equality, lies at the heart of our new constitutional order.21

41. Langa J expressed it as follows:

The Constitution is located in a history which involves a transition from a society based on division, injustice and exclusion from the democratic process to one which respects the dignity of all citizens, and includes all in the process of governance. As such, the process of interpreting the Constitution must recognise the context in which we find ourselves and the Constitution's goal of a society based on democratic values, social justice and fundamental human rights. This spirit of transition and transformation characterises the constitutional enterprise as a whole.22

42. It would be idle to suggest that this transformation has been achieved. We live amidst deep inequality and poverty, which in substantial measure are the legacy of colonialism and apartheid. A call to renew the struggle for transformation is not lightly to be declared impermissible. This is particularly so where the governing statute is the Equality Act, which states in sec 4(2)(a) that when applying the Act, cognisance should be taken of the existence of systematic discrimination and inequalities particularly in respect of race, gender and disability brought about as a result of colonialism and apartheid.

43. Again, it is therefore necessary to examine the context in order to establish whether this (a call to renew the struggle for transformation) is the intention which a reasonable person would attribute to the speaker or singer. This too is a possible intent of singing a rousing song which invokes the memory of past struggle.

(v) The identity of the perpetrator

44. The identity of the perpetrator may be relevant in two ways.

45. On the one hand, the more privileged and powerful the perpetrator is relative to the "target" group, the greater the potential harm. This appears from the judgments of the European Court of Human Rights on anti-immigrant speech by politicians.23 The Court has held that the greater threat of harm may require the courts to subject a politician's speech to closer scrutiny for potential hate speech.

46. On the other hand, there is a tendency to adopt a more lenient approach where the alleged perpetrator is from an oppressed or marginalised group. Michael Rosenfeld24 contends that it is understandable that groups that have experienced historical oppression and on-going disadvantage may vent their frustration or seek to build a sense of solidarity by using language that is less than temperate, and may amount to hate speech if used by historically dominant groups. As a result, Rosenfeld argues that "[r]eaction by the oppressed even if tinged with hatred should ... be somewhat more tolerated then hate messages by members of traditionally oppressor groups."

47. The High Court referred to its duty to protect "particularly vulnerable" minority groups.25  However, we submit that its application of this duty was altogether too simple. It may be argued that Mr Malema was a powerful individual, and that a reasonable person would take his utterances seriously and attribute serious intention to them, because they may have serious consequences. However, this cannot be generalised to all persons who might sing the song. Very many of them will be marginalised people, notwithstanding that they are members of a group which is numerically in the majority.

48. The High Court accepted without qualification a definition of "minority" based on numerical inferiority.26  However, the matter is more complex than that.

49. The Report of the United Nations Office of the High Commissioner for Human Rights, "Minority Rights: International Standards and Guidance for Implementation", states "There is no internationally agreed definition as to which groups constitute minorities."27 The Report explained that "In most instances, a minority group will be a numerical minority, but in others, a numerical majority may also find itself in a minority-like or non-dominant position, such as blacks under the apartheid regime in South Africa."28

50. Even in a democracy, groups that are a numerical majority may occupy a culturally and economically subjugated position. South Africa today illustrates this. We submit that the approach of the High Court, treating the black majority in South Africa as one dominant mass, over-simplified the relationship between the Afrikaner "minority" and the "majority". The "target" group continues to command vast  social, material and cultural capital, certainly in comparison with the majority of the nation's citizens.

V: CONCLUSION

51. Sections 3(1)(a) and (b) of the Equality Act state that when applying the Act, regard must be had to the inequalities which came about as a result of apartheid and colonial discrimination. Many of those inequalities remain with us. The purpose of the Act is to redress inequality.

52. It is important that the law should not be used to continue the marginalisation of vulnerable groups, or in a manner which silences the voices of groups that are previously oppressed. The ban imposed by the High Court has the potential of silencing the very voices that were silenced during apartheid.

GEOFF BUDLENDER SC 
TEMBEKA NGCUKAITOBI

Chambers, Cape Town and Johannesburg

2 August 2012

"We acknowledge with appreciation the assistance of research conducted by Oxford Pro Bono Publico, a programme of the Law Faculty of the University of Oxford."

LIST OF AUTHORITIES South African cases

Mankayi v Anglogold Ashanti Ltd 2011 (3) SA 237 (CC) para [71].

Le Roux and others v Dey 2010 (4) SA 210 (SCA) para [7].

Le Roux and others v Dey (FXI and Restorative Justice Centre as Amici Curiae)

2011 (3) SA 274 (CC).

Soobramoney v Minister of Health, KwaZulu-Natal 1998 (1) SA 765 (CC) at [8]

Investigating Directorate: Serious Economic Offences v Hyundai Motor Distributors (Pty) Ltd; in re Hyundai Motor Distributors (Pty) Ltd v Smit NO 2001 (1) SA 545 (CC) at [21]

Standard General Insurance Co Ltd v Commissioner for Customs and Excise 2005 (2) SA 166 (SCA) para [37]

Judgments from other jurisdictions

Bropho v Human Rights & Equal Opportunity Commissioner (2004) 135 FCR 105 at 128

Vajnai v Hungary App. no 33629/06 (ECtHR, 8 July 2008) Fratanolo v Hungary App no 29459/10 (ECtHR 3 November 2011). Ramesh v Union of India (1988) 1 SCC 668

Anand Patwardhan v Union of India AIR 1997 Bom 25

F.A. Picture International v Central Board of Film Certification AIR 2005 Bom 145

Shrishti School v Chaiperson, Central Board of Film Certification WP (C) 6806 of 2010 [23].

Le Pen v France, App no. 18788/09 (ECtHR 20 April 2010)

Féret v Belgium App no. 15615/07 (ECtHR 16 July 2009)

Other writings

Michael Rosenfeld "Hate Speech in Constitutional Jurisprudence: A Comparative Analysis" (2003) 24 Cardozo Law Review 1523, 1528.

United Nations Office of the High Commissioner for Human Rights: Minority Rights: International Standards and Guidance for Implementation

Footnotes:

1 Judgment Vol 11 p 1997 para 91

2 Judgment Vol 11 p 1970 para 35 and 36

3 Judgment Vol 11 p 2000 para 94

4 Judgment Vol 11 p 2006 para 105

5 Judgment Vol 11 p 2008 para 108

6 Mankayi v Anglogold Ashanti Ltd 2011 (3) SA 237 (CC) para [71].

7 Section 2(b)(v). See also the Preamble.

8 This qualifying clause was omitted by Lamont J when he quoted sec 10: Judgment Vol 11 p 1963 para 23.

9 Le Roux and others v Dey 2010 (4) SA 210 (SCA) para [7]. The judgment was reversed in Le Roux and others v Dey (FXI and Restorative Justice Centre as Amici Curiae)2011 (3) SA 274 (CC). However, the Constitutional Court did not reject the proposition that when adjudicating a claim of defamation, regard must be had to the nature of the audience.

10 (2004) 135 FCR 105 at 128

11 See for example Standard General Insurance Co Ltd v Commissioner for Customs and Excise 2005 (2) SA 166 (SCA) para [37]

12 Judgment Vol 11 p 1998 para 93.

13 Vajnai v Hungary App. no 33629/06 (ECtHR, 8 July 2008)

14 Fratanolo v Hungary App no 29459/10 (ECtHR 3 November 2011).

15 Vajnai para [52].

16 Para [51] (emphasis added); see also Fratanolo para [25].

17 Vajnai para [54]; Fratanolo para [25].

18 Vajnai ibid [57].

19  See for example Ramesh v Union of India (1988) 1 SCC 668; Anand Patwardhan v Union of India

AIR 1997 Bom 25; F.A. Picture International v Central Board of Film Certification AIR 2005 Bom 145.

20 Shrishti School v Chaiperson, Central Board of Film Certification WP (C) 6806 of 2010 [23].

21    Soobramoney v Minister of Health, KwaZulu-Natal 1998 (1) SA 765 (CC) at [8]

22    Investigating Directorate: Serious Economic Offences v Hyundai Motor Distributors (Pty) Ltd; in re

Hyundai Motor Distributors (Pty) Ltd v Smit NO 2001 (1) SA 545 (CC) at [21]

23 Le Pen v France, App no. 18788/09 (ECtHR 20 April 2010); Féret v Belgium App no. 15615/07 (ECtHR 16 July 2009)

24 Michael Rosenfeld "Hate Speech in Constitutional Jurisprudence: A Comparative Analysis" (2003)

24 Cardozo Law Review 1523, 1528.

25 Judgment Vol 11 p 1970 para 35

26 Judgment Vol 11 p 1971 para 36

28 United Nations Office of the High Commissioner for Human Rights: Minority Rights: International Standards and Guidance for Implementation

Source: www.casac.org.za

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