Israel has knowingly and deliberately continued to act in defiance of the [International Court of Justice] Order. In addition to causing the death by starvation of Palestinian children in babies, Israel has also continued to kill approximately 4,548 Palestinian men, women and children since 26 January 2024, and to wound a further 7,556, bringing the grim totals to 30,631 killed and 72,043 injured. An unknown number of bodies remain buried under the rubble. 1.7 million Palestinians remain displaced — many of them permanently, Israel having damaged or destroyed approximately 60 per cent of the housing stock in Gaza. Approximately 1.4 million people are squeezed into Rafah — which Israel has stated it intends to attack imminently. Israel’s destruction of the Palestinian healthcare system has also continued apace, with ongoing, repeated attacks on hospitals, healthcare, ambulances and medics. Israel has also continued to conduct widespread attacks on schools, mosques, businesses and entire villages and areas.
IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA
In the matter between:
THE ECONOMIC FREEDOM FIGHTERS Applicant//
and
THE SPEAKER OF THE NATIONAL ASSEMBLY
REPUBLIC OF SOUTH AFRICA First Respondent
PRESIDENT JACOB GEDLEYIHLEKISA ZUMA Second Respondent
NOTICE OF MOTION
TAKE NOTICE that in terms of the provisions of sections 167(4)(e), 167(6)(a) of the Constitution and rule 18 of the rules of the Constitutional Court, the applicant makes application to this Court for final relief in the following terms:
TAKE NOTICE THAT the founding affidavit of Mr Floyd Nyiko Shivambu annexed hereto and its annexures shall be used in support of this application.
TAKE NOTICE FURTHER that the Chief Justice is requested to issue directions concerning the manner in which this application shall be dealt with.
DATED AT JOHANNESBURG ON THIS THE 4th DAY OF AUGUST 2015.
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