Advocate Ramsamy

Adv Serunye states Advocate Ramsamy was also involved but was off sick that morning and she was not a DDPP.

“ADV SERUNYE and ADV KHUMALOSC”

The matter was proceeding without a DDPP and project owner, implying that even with Advocate Ramsamy assisting, it was still junior prosecutors handling the case, which was a concern due to the involvement of high-level SAPS officials.

“ADV KHUMALOSC”

Advocate Ramsamy saw the section 27 referral document in the earlier part of the case but could not provide a copy as it was returned to the Investigating Directorate (ID) and appears to have been lost or is untraceable.

“Advocate Ramsamy said she saw it, I think in the earlier part of the case when they were starting the investigations. But it appears either it was lost or disappeared ... She said she gave it back to the ID. But it appears the ID was also looking for it from her.”

An ID investigator met with Advocate Serunye and others to confront her about her persistent requests for the section 27 document, angrily telling her the ID had seen the document and questioning her trust in the investigators.

“ADV SERUNYE”

Advocate Santos Manilall was the Deputy Director of Public Prosecutions (DDPP) and project owner of certain cases, taking over from Advocates Ramsamy and Hlatshwayo who ceased to be prosecutors in those cases.

“they were later then involved with Advocate Santos Manilall being the DDPP and project owner of this case. When I ceased to be the prosecutor in the case, I think so was Advocate Ramsamy and Advocate Hlatshwayo. So the team led by Advocate Manilall took over the two cases”

The team led by Advocate Manilall took over certain cases, with Advocates Ramsamy and Hlatshwayo no longer being part of the prosecution team.

“The team of Advocate Manilall took over the two cases and Advocate Ramsamy ceased to be the prosecutor in the Lushaba case, so did Advocate Hlatshwayo.”

ADV SERUNYE tried to mediate between Investigators especially Brian Padayachee and Advocate Ramsamy who were not on speaking terms.

“The relationship was not that good ... especially Brian Padayachee and Advocate Ramsamy. They were not in speaking terms when I came into the team. So I tried to put them together. In some of my emails, I am saying to them ... we are playing for the same team”

Adv Serunye sent a 'Saturday homework' email to team members including Advocates Hlatshwayo, Ramsamy, Mr Brian Padayachee, Chief Investigator Daylan Perumal, Investigator Charles Eales, Investigator Patrick Mlambo, and project manager Mr Sipho Tlale to keep the team informed and attached queries for trial preparation.

“I sent it at 2.51 on the Saturday to the team members, Advocate Hlatshwayo, Advocate Ramsamy, Mr Brian Padayachee, Chief Investigator Daylan Perumal, Investigator Charles Eales, Investigator Patrick Mlambo. And I also copied the Project Manager, Mr Sipho Tlale... I sent them this email, and the email had an attachment containing queries”

A D V B A L O Y I S C states that the internal prosecutors for this case would have been Ms Hlatshwayo and Ms Ramsamy.

“In this case, the internal prosecutors would have been either or both Ms Hlatshwayo and Ms Ramsamy.”

Advocate Serunye was asked to oversee the Lushaba matter but found no case on the docket and questioned why General Lushaba, the victim, had been charged.

“I was also asked to oversee the Lushaba matter, in which Advocate Ramsamy was the lead prosecutor. Having considered the docket, I was of the view that it disclosed no case. In particular, I did not understand why the complainant, General Lushaba, who on the face of the docket was the victim, had been charged.”

There is usually a handover report when a docket and investigation move from one team to another, but it is unclear if Advocate Hlatswayo or Advocate Ramsamy performed a handover in this case.

“Ideally , in a normal setup , there should be a handover report . In this case , I am not sure if Advocate Hlatswayo , who I left in the Mokwele / Khumalo case , did a handover . I am not sure if Advocate Ramsamy did a handover on this one .”

Advocate Ramsamy was responsible as the prosecutor in the case related to the chargesheet discussed.

“She was the prosecutor in the case .”

A debate has been had about whether gratification charges were properly formulated based on facts, with Advocate Serunye expressing difficulties; the same discussion occurred with the ID, Mr Padayachee, and Ms Ramsamy, indicating these charges are a default fallback in at least these cases.

“We have had the debate about gratification , whether the charge has been – the charge is properly formulated on your facts , and you have expressed your difficulties with it . The same discussion was had with the ID , the same discussion was had with Mr Padayachee and Ms Ramsamy . So at least on these two cases , it seems to have been a default , maybe because nothing else works .”

Advocate Serunye and two prosecutors, Hlatshwayo and Ramsamy, raised complaints about investigators not listening to prosecutors and other issues in their emails and memos around August 2025.

“I was also getting complaints from the prosecutors, Advocate Hlatshwayo and Advocate Ramsamy, saying about how the investigators are not listening ... some of the issues that I have been raising in my emails and in my memos, the two prosecutors also did the same. They showed me a document directed to the office of the ID with a lot of queries around August 2025.”

Advocate Johnson gave instructions approving an appeal based on Mr Padayachee’s affidavit and sent a WhatsApp message instructing Advocate Ramsamy to inform Advocates Serunye and Hlatshwayo, though Advocate Hlatshwayo did not ask for the bail condition in court.

“Advocate Johnson gave instructions approving the appeal based on Mr Padayachee's affidavit and she then sent a WhatsApp to Advocate Ramsamy, instructing her to then inform Advocate Serunye and Advocate Hlatshwayo... but Advocate Hlatshwayo did not ask for that condition in court.”

In a past Section 27 referral investigation, the lead prosecutor provided all necessary and relevant information forthwith, but in the current Section 27 referral (Fidel Adams matter), information was not forthcoming and investigators were told they would not receive Section 27 documents by Advocate Ramsamy.

“the lead prosecutor that we worked with on the first one, she provided all the information that was necessary ... But when it comes to this one, the information was not forthcoming ... It was made clear that we will not be getting that section 27 ... The advocate, Advocate Ramsamy, indicated that we should not be provided with that document”

On the morning of the 6th, Advocate Ramsamy provided Mr. Raphesu with an affidavit later known as section 27.

“I was approached by Advocate Ramsamy, who provided me with the, I will just say an affidavit that later became known as a section 27.”

The section 27 affidavit Mr. Raphesu saw in file two at page 512 is different and has material features not seen in the document shown to him by Ms. Ramsamy on 6th December.

“And you note that there were material features that you do not see in this one that you saw in the one that Ms Ramsamy shared with you? ... That is correct, Chair.”

The affidavit that Ms Ramsamy gave to Mr Raphesu contained various matters related to the PKTT, including references to Orlando CAS numbers and Villieria but not Cape Town CAS numbers.

“the affidavit that Ms Ramsamy gave you contained various matters related to the PKTT”

The section 27 affidavit contained all allegations related to General Madondo and failing of a polygraph test.

“the section 27 that Ms Ramsamy showed you contained allegations related to General Madondo and failing of a polygraph test”

Mr Raphesu briefly browsed the affidavit for between 5 to 10 minutes and did not finish reading it before pushing it back to Ms Ramsamy as she was about to leave, because it was supposed to be handed over to Advocate Johnson's safe.

“the time might be maybe between 5 to 10 minutes ... then I pushed it back to her when she was about to leave ... she was supposed to have handed it over to be kept at the safe of Advocate Johnson”

Mr Raphesu was alone with Ms Ramsamy when he received and browsed the affidavit; Mr Perumal and Padayachee were not present.

“No, they were not there. It was just the two of us”

There was a common understanding of non-verbal communication between Mr Raphesu and Ms Ramsamy; if she was looking around when handing a document, it meant he should be quicker and that he was not supposed to be looking at that document at that time.

“when she gave you the document, she was looking around ... you understood to mean you were not supposed to be looking at that document at the time”

Mr Raphesu stated that on the previous 27 project, they had problems with Chief Perumal who sometimes tried to come with tricks, so they had to unite to deal with his dodgy ways.

“we had problems with Chief Perumal. So he sometimes wanted to come with tricks and other things. So we had to unite so that we can be able to deal with his dodgy ways”

Mr. Raphesu testified that when Advocate Ramsamy asked Mr. Fadiel about documents, he was told Fadiel had already given the documents to Chief Perumal just before the interviews started.

“when Advocate Ramsamy asked him about the documents, Mr Fadiel already told us that he gave the documents to Chief Perumal just before the interviews started”

There was no occasion when Chief Perumal was alone with Mr Adams, without MR RAPHESU or Advocate present.

“Was there an occasion or a moment when the two of you were somewhere else , and Mr Perumal was alone with Mr Adams ? No , that never occurred , Chair .”

Advocate Ramsamy instructed Mr Raphesu to draft a section 28 subpoena regarding General Lushaba's bank records, but Mr Raphesu refused to do so as there was no docket reference and he feared he could not explain his actions later.

“… Advocate Ramsamy came to my office with a piece of paper indicating that the head of the office, Advocate Johnson, wanted me to draft a section 28 subpoena. So I had a conversation with Advocate Ramsamy to say, but this we cannot do because we do not have anything in the docket ... if we do this, I am not going to be able to explain why I subpoenaed these documents.”

Mr Raphesu was harsh to Advocate Ramsamy when he first heard about the R50 million subpoena request but later sent a WhatsApp message to suggest stalling until more information was received.

“So I was a bit harsh on her to say, no, I cannot do it ... eventually she said she is going to take my message back ... so I did send a WhatsApp to say, can we at least stall or maybe wait until we get further information before we move on this?”

Mr Raphesu sent a message on 11 December 2024 to Advocate Ramsamy suggesting to stall or park the preparation of section 8 documents until consulting with the complainant.

“Good morning Advocate Drew ... I was suggesting that we stall or park it until we consult with the complainant ... so that after consultation we could move faster.”

Ms Ramsamy did not take kind of me questioning her; she instructed Mr. Raphesu to draft section 28 documents regarding information about the 50 million slush funds.

“she indicated that the ID did not take kind of me questioning her. So we were summoned now to Advocate Johnson's office, where now, she now instructed me to draft this section 28”

Ms Ramsamy had a piece of paper with information about General Lushaba including his ID number, which Mr. Raphesu used to subpoena using the ID number.

“On the piece of paper, it was just information about General Lushaba, but what I could pick up there, it was the ID number. So I had to do the subpoena on his ID number.”

Mr. Raphesu did not get a chance to speak in the meeting with Advocate Johnson; he assumed Ms Ramsamy conveyed his issues and the meeting was to give instructions, not a consultation.

“I did not even get a chance to speak. So I assume that when Advocate Ramsamy went to her, she said enough... No, it was just there to give the instructions.”

The two other investigators were not allowed to proceed with investigations or interviews without Mr. Raphesu's knowledge and consent, and affidavits must be discussed with the lead prosecutor before being authorised.

“they were not allowed to... the prosecution led indicates that before an affidavit can be authorised, it must be discussed with the lead prosecutor... So when Advocate Ramsamy comes with the presentation, I think she will be able to complete that part... But from your question, they were not supposed to have done that.”

M R R A P H E S U raised the issue of early 204 statement taking with Ms Ramsamy and Mr Sesoko, and was advised to concentrate on the Lushaba matter, while the other two persons would continue with their matters.

“No, they gave me feedback. They indicated that I should continue concentrating on the Lushaba matter and the other matter, the other two guys will continue with it... and Mr Padayachee assumed the responsibility of being a lead on that other matter.”

Ms Ramsamy confirms that the discussions about the investigation authorization were kept between herself, Mr S, and Dylan.

“Ms Ramsamy confirms that they have been keeping that between Mr S, myself, and Dylan.”

Ms Ramsamy made certain disclosures to a DPCI officer regarding matters in the Mokwele investigation and wanted to consult on these matters.

“Ms Ramsamy had made certain disclosures to him regarding these matters and had wanted to consult on the matters”

Ms Ramsamy was aware of the serious allegations she was making but did not want them put to Advocate Johnson until she could give her full version under protected disclosure protection.

“She was aware of the allegations that she was making, that they were serious, but had not wanted them to be put to Advocate Johnson until she had been given an opportunity to give her full version, because her intention was in any event to only make this disclosure under protected disclosure protection after Advocate Johnson gave her evidence”

Advocate Johnson gave evidence on 22 July implicating Ms Ramsamy in events related to the Mokwele investigation, which led to Ms Segels-Ncube receiving information about Ms Ramsamy's disclosures during that evidence.

“on the 22nd of July, when Advocate Johnson gave evidence regarding certain events that occurred in the Mokwele investigation, she mentioned the name of Ms Ramsamy... I received a message from a DPCI officer who had indicated to me that Ms Ramsamy had made certain disclosures...”

Ms Ramsamy is a witness in the Commission and has given a statement dated 30 July 2026.

“Ms Ramsamy confirmed that her signature on the statement at page 1 to 33 was hers and that it was signed this morning, the 30th”

Ms Ramasamy is a full-time employee of the National Prosecuting Authority (NPA) attached to the Investigating Directorate Against Corruption (IDAC), joined as a state advocate on 1 March 2023.

“I am an adult female admitted attorney in the full-time employee of the National Prosecuting Authority, attached to the Investigating Directorate Against Corruption, commonly known as IDAC ... I joined the IDAC as a state advocate on the 1st of March 2023.”

Ms Ramasamy holds an LLB degree from the University of KwaZulu-Natal and was admitted as an attorney of the High Court of South Africa on 7 June 2013.

“I hold an LLB degree obtained from the University of KwaZulu-Natal, and I was admitted as an attorney of the High Court of South Africa on the 7th of June 2013.”

Ms Ramasamy was appointed as an aspirant prosecutor in Pietermaritzburg, KwaZulu-Natal on 1 February 2015, and worked on drug-related prosecutions in the Pinetown cluster, KwaZulu-Natal from 2016 to 2020, collaborating closely with SAPS members including Karl Saunder.

“I was appointed as an aspirant prosecutor in Pietermaritzburg-KwaZulu-Natal on the 1st of February 2015 ... I was based within the Pinetown cluster, KwaZulu-Natal, from the period of 2016 to 2020. During this period, I have dealt with drug-related prosecution and worked closely with SAPS members, such as Karl Saunder, who has given evidence before this Commission.”

Ms Ramasamy was a Regional Court prosecutor in Pretoria CBD before joining IDAC on 1 March 2023.

“I was a Regional Court prosecutor in Pretoria Court, CBD, and I was then appointed as a state advocate on the 1st of March 2023 in the Investigating Directorate, IDAC.”

The Medicare 24 investigation was initially disguised under the title 'Tembisa' in emails and meetings to obscure what was actually being investigated, according to Ms Ramasamy.

“In my second statement...what was initially titled as Tembisa, which was actually the Medicare 24, becomes Project Wellness... it progresses in terms of names and disguising.”

Advocate Johnson initiated emails with the subject line referring to Tembisa, which were later used to cover Project Diversion and Medicare 24 related investigations.

“Who initiated the emails referring to Tembisa? Advocate Johnson... It later then, Advocate Johnson would title projects, like the Crime Intelligence became known as Project Diversion...”

Advocate Johnson made untruthful statements about Ms Ramasamy's involvement in the Mokwele case and did not disclose that Ms Ramasamy raised concerns repeatedly from the onset.

“Advocate Johnson told many untruths about me and my involvement in what is now known as the Mokwele case. She did not disclose that I raised concerns from the onset and repeatedly thereafter...”

Ms Ramasamy believes that Advocate Johnson handpicked her for Project Diversion because of her successful investigation of a high-profile individual in another section 27 referral matter and because she thought Ms Ramasamy would not question or ask questions.

“It is my belief that Advocate Johnson hand-picked me to be part of this project because I had successfully, or rather we had successfully, investigated another section 27 referral matter involving a high-profile individual. I also believe that Advocate Johnson picked me because she thought that I would not question or ask questions because I am a state advocate.”

Ms Ramasamy and Mr Mansha Raphesu, the lead investigator, questioned Project Diversion from the start contrary to Advocate Johnson's expectations.

“What she did not anticipate was that Mr Raphesu, Mansha Raphesu, the leading investigator, and I would question Project Diversion from the start.”

Ms Ramasamy prepared documents on Advocate Johnson's instructions that were not in accordance with IDAC standard operating procedures, although IDAC SOPs do exist.

“I confirmed that I prepared documents on Advocate Johnson's instructions that we: not in accordance with IDAC standard operating procedures, which Advocate Johnson indicated to this Commission did not exist.”

The draft section 28(13) application corroborates the version of the section 27 referral affidavit seen on 5 December 2024, when the application was drafted.

“My draft section 28(13) application is also corroboration of the version of the section 27 referral affidavit that I saw on the 5th of December 2024, when I drafted the application.”

On 9 October 2025, MS Ramsamy was contacted by Innocent Sekokane, personal assistant to Advocate Johnson, about Mr Perumal calling regarding whereabouts of the original section 27 referral affidavit, and said MS Ramsamy was asked to keep it safe but could not trace the affidavit.

“On the 9th of October 2025, I was contacted by Ms Innocent Sekokane, personal assistant to Advocate Johnson. She informed me that she was told that Mr Perumal had called me that same day regarding the whereabouts of the original section 27 referral affidavit. She said that I had to told Mr Perumal that I was tasked with the safekeeping of the section 7 referral affidavit and that I could not trace the section 27 referral affidavit.”

In September or early October 2025, accused persons in the Mokwele matter made numerous requests for the section 27 referral affidavit. Advocate Johnson and Mr Perumal were struggling to find it and possibly thought MS Ramsamy had it, but MS Ramsamy suspects they did not want to disclose the affidavit to the accused and needed a reason why it could not be produced.

“If I recall correctly, in September 2025 or early October 2025, the accused persons in the Mokwele matter had made numerous requests for the section 27 referral. I want to say that Advocate Johnson and Mr Perumal were struggling to find the section 27 referral affidavit and perhaps thought I had the affidavit, but I cannot say that because what I suspect is that Advocate Johnson and/or Mr Perumal did not want to disclose the section 27 referral affidavit to the accused persons in the Mokwele matter and needed a reason as to why it could not be produced.”

MS Ramsamy was concerned about being blamed unfairly for something she had no knowledge of and addressed an email to Advocate Johnson about events on 5 December 2024 and thereafter, regarding the section 27 referral affidavit.

“I was concerned that I was being blamed for something I had no knowledge of. I addressed an email to Advocate Johnson to set out the events that transpired on the 5th of December 2024 and thereafter, regarding the section 27 referral affidavit. I have provided the email to the Commission.”

On 9 October 2025, MS Ramsamy sent an email to Advocate Johnson, Mr Perumal, Mr Sesoko, and Mr Tlale saying that she was contacted by Enoch, that Mr Perumal had directed her to keep the section 27 referral affidavit safe but she could not trace it, and that Mr Perumal did not contact her that day but Mr Tlale did.

“Good day, Advocate Johnson. I was contacted by Enoch, in respect of: That I was contacted by Mr Perumal today regarding the above referral, and that I indicated you told me to keep it safe, and that I cannot trace it. Mr Perumal did not contact me today. Mr Tlale contacted me today. He contacted me this morning, and I explained to him as follows: On the morning of the 5th of December 2025 ...”

MS Ramsamy was instructed to return the folder containing the section 27 affidavit documents to the office the next day and not to make any copies, putting the documents in a large brown envelope because the grey document bag was conspicuous.

“Your instructions regarding the folder was that I was returned it to your office the next day, and no copies of the documents were to be made. Because the grey document bag was conspicuous, I put it in a large brown envelope and returned the same to your office before the staff meeting on the 6th of December 024.”

MS Ramsamy did not retain possession of the original section 27 affidavit referral nor any copies and returned it to the office the same day after receiving it.

“I wish to state I did not retain possession of the original section 27 affidavit referral, nor any copies thereof. As instructed, I returned the same to your office on the same day after receiving it.”

MS Ramsamy's last communication with Mr Perumal was on 18 September 2025 via WhatsApp text, so she could not have told him she was asked to keep the affidavit safe and that she misplaced it.

“I did not have any communication with Mr Perumal today. Our last communication was on the 18th of September 2025, via WhatsApp text. Thus, I could not have told him that I was asked to keep it safe, and I misplaced it.”

Advocate Johnson responded to MS Ramsamy's email later the same day via WhatsApp, accepting she may have been mistaken about the section 27 referral affidavit and said she would check her office the next day.

“Later the same day, at 3 or 4 p.m., Advocate Johnson responded to my email via WhatsApp. In the message, she accepted that she may have been mistaken about the section 27 referral affidavit. She said she would look in her office the following day.”

There are great discrepancies between what transpired with the arrests and what is contained in the section 27 affidavit.

“there is great discrepancies”

Advocate Johnson gave Ramsamy a handwritten pink-purple page with the names of suspects for the section 28(13) authorization list.

“she gave me a list of suspects' names on the pink-purple notepad page”

The names in the section 28(13) authorization were sourced from Advocate Johnson and a section 27 referral affidavit.

“I got the names from Advocate Johnson, together with the section 27 referral affidavit”

Advocate Johnson made a startling remark that they must find a way for Ramsamy not to testify before the Commission.

“Advocate Johnson made a startling remark, that we have got to figure out how you do not go.”

Ramsamy was unsure where the names on the handwritten page came from, but Johnson explained the suspects list came after Dylan consulted Fadiel.

“the suspects was after Dylan had consulted Fadiel . That is how the list came about.”

Advocate Johnson says Dylan cannot remember many things and Ramsamy has no power abuse in authorizing names of others in the section 28(13).

“He cannot remember half the things”

Ramsamy sent an email explaining what she received and what she returned to Advocate Johnson concerning the suspect list.

“after you phoned me last night, I went and found that email where I explained what I received from you and what I returned to you.”

Advocate Johnson signed the section 28(13) authorization but indicated Ramsamy did not prepare an application for it as normally done, instead a short summary with facts is usually given to authorize Drew.

“Yes, but did you put an application together for the authorisation? ... usually we just put a thing with a short summary of facts.”

Ramsamy was told not to do a mandate memo and that facts were covered in the email sent.

“you told me not to do the mandate memo. It was just the ... I am just opening my laptop for you now ... the facts and all of that was covered in the email I sent.”

Ms Ramsamy sent Advocate Johnson a WhatsApp message on 10 December 2024 with a summary and preliminary instructions for the team but was not instructed to prepare the report.

“On the morning of the 10th of December 024, three business days after the preparatory investigation was authorized, I sent Advocate Johnson a WhatsApp message informing her that I had prepared a summary and a preliminary instruction for the team. I was not instructed to prepare this report.”

Ms Ramsamy instructed that no section 28 subpoenas should be issued without her perusal and signature, but Advocate Johnson overruled this instruction and dictated Project Diversion with Mr Perumal.

“She was instructing me to issue section 8 summonses notwithstanding my instructions to the investigators not to do so without my perusal. In effect, she overturned my instructions and this illustrates how Project Diversion was dictated by her and Mr Perumal.”

Urgent summons for bank records do not prevent dissipation of funds and only show movement of funds unless there is evidence of intent to dissipate, which Ms Ramsamy found lacking.

“The bank records would merely show the movement of the funds. It would have been different if we had evidence that there was an attempt to dissipate the funds and sought an urgent order to freeze the account. If there was a prima facie case, obtaining bank statements on an urgent basis would serve no purpose.”

Ms Ramsamy forwarded Advocate Johnson's message to a Signal group chat including Perumal, Padayachee, and Raphesu before calling Mr Perumal as instructed.

“Before I called Mr Perumal, I forwarded Advocate Johnson's message to a Signal group chat with Perumal, Padayachee and Raphesu in the group. Thereafter, I called Mr Perumal as instructed.”

The decision to issue section 28 summonses was made by the Chief Investigator and Head of IDA, despite lack of prima facie evidence and Ms Ramsamy's concerns.

“It was clear to me that the decision had been made that the summonses would be issued if both the Chief Investigator and the Head of IDA have decided that it should be.”

The section 28 (13) summons is supposed to be issued only after it is signed off and there was no project manager included in the team when it was signed on 6 December, which indicates faulty process.

“The CIN number is supposed to be issued on the day that the 28 (13) is signed off. ... If you look at the composition of the team on the 28 (13) signed on the 6th of December, there is not a project manager. The project manager is only allocated after everything is done and that is why I say the whole process of this 28 (13), using Chair's favourite word, is "deurmekaar".”

Dylan has emails on his phone relevant to the names and documents that were slotted under Fadiel's door, including a chain of emails between Dylan and MS Ramsamy about these matters.

“But ask Dylan to check because he has his emails on his phone . There is an email between him , you and I , about the names as well as about the documents , the ones that were slotted under Fadiel 's door . So there was a chain email between us , he should remember .”

ADV Johnson was Respected and called 'Mama' by MS Ramsamy due to her kindness and support, despite issues with work ethic.

“When I started with ID , before it became IDAC , Advocate Johnson was the Head of Office . We had a choice between calling her ID or Mama J . And I respectfully call her that because she is not a bad person . She is not . You know , when I got sick , she was there . She is kind . It is just the work ethic that I have a problem with . And so I respectfully call her Mama .”

MS Ramsamy expressed unease with being instructed to include names of suspects in the section 28(13) application since it did not reconcile with the content of the section 27 referral affidavit.

“paragraph 49: Mr Raphesu briefly perused the affidavit before I had to return it to Advocate Johnson, shortly before the staff meeting. I went to Advocate Johnson 's office and returned the section 27 referral affidavit, and she gave me the signed 28(13) authorisation. There was a meeting scheduled for 11 a.m. with the team assigned to the Adams referral, which took place in Advocate Johnson's office.”

Ms Ramsamy contacted the Directorate of Priority Crime Investigation (DPCI) because of discord among the Crime Intelligence Investigation team and sloppy investigation procedures regarding Project Diversion.

“I contacted DPCI because I had previously, in late April 025, informed Advocate Santhos Manilall, the DDPP, of the discord amongst the team, the team being that of the Crime Intelligence Investigation, and that the investigation procedures were being flouted and that the investigation was sloppy.”

Advocate Peter Serunye, Deputy Director of Public Prosecution, came onboard the Mokwele and Lushaba cases and sent emails and memoranda supporting Ms Ramsamy's concerns about the Mokwele matter.

“On the 8th of August 2025, Advocate Peter Serunye, a Deputy Director of Public Prosecution, came on board the Mokwele and Lushaba cases. He started sending emails and memoranda that accorded with my concerns on how the Mokwele matter was being conducted.”

Ms Ramsamy was removed from the Mokwele case and excluded from the Lushaba case from September 2025 after Advocate Serunye requested removal from those cases.

“When Advocate Serunye requested to be removed from the Mokwele and Lushaba cases, I was removed from the Mokwele case, and although I was apparently kept on the Lushaba case, I was excluded from the case from September 2025.”

Another Deputy Director told Ms Ramsamy that concerns she showed him would never come to light, implying suppression of information.

“I also approached another Deputy Director and showed him all the documentation that were concerning. He stated these things will never come to light.”

In November 2025, Ms Ramsamy reported to DPCI that Advocate Johnson lied to the Ad Hoc Committee and provided proof.

“In November 2025, after Advocate Johnson testified at the Ad Hoc Committee, I contacted the same officer at the DPCI. I informed him that Advocate Johnson had lied to the Ad Hoc Committee and that I had proof of this.”

Ms Ramsamy met with DPCI officer around March 2026 after the appointment of the new NDPP Advocate Mothibi because nothing would have been done with the previous NDPP regarding her concerns about Advocate Johnson.

“Once the new NDPP, Advocate Mothibi, was appointed, I met with the DPCI officer. This would have been around March 2026. ... Because I knew that if I had reported or we had taken these concerns to the then-sitting NDPP, nothing would have been done.”

A Deputy Director of Public Prosecution said to Ms Ramsamy after she showed him concerning documentation that these things will never see the light of day, which Ms Ramsamy understood as an intent to suppress and destroy evidence.

“The DDPP, and he said these things will never see the light of day. ... That no one will ever know that these things were done by Advocate Johnson or at IDAC.”

Ms Ramsamy is concerned that by coming forward with information against Advocate Johnson she is being made a scapegoat and fears retaliation.

“I mention this because I do not want the narrative to be that I am retaliating against Advocate Johnson for making me the scapegoat or that I am coming forward with this information now that my name has been dragged through the mud.”

Ms Ramsamy provided documents showing the standard operating procedure and case selection criteria directives issued and signed by Advocate Johnson and Mr Matthew Sesoko, Head of Investigation, in October 2024 and August 2022 respectively.

“I will deal with the section 27 referrals based on my personal experience and understanding of the SOP, case selection, criteria directive issued and signed by Advocate Johnson and Mr Sesoko in October 2024 and in August 2022 respectively.”

Mr Ramsamy doubts Mr Padayachee's version that he did not see the section 27 referral affidavit due to secrecy around it and evidence from Mr Perumal's comments.

“There was a lot of secrecy around this section 7 referral affidavit. Had it not been for Mr Perumal's comments at the airport, I would have believed Mr Padayachee that he had not seen the section 27 referral affidavit.”

Mr Ramsamy cannot confirm the date of the section 27 affidavit seen but has recollections of conversations and WhatsApp messages from November 2024 relating to the 27 referral email debacle.

“I cannot confirm that. I have a recollection of a different date. I also have a recollection of a conversation between Perumal and myself, when this whole debacle of where is the 27 referral as per my email was happening, where Perumal says to me, no, the ID must check, the ID must check, referring to Advocate Johnson, because I have WhatsApps from the 13th of November where Fadiel is asking for things.”

Advocate Johnson provided instructions that the dockets must be photocopied immediately and originals handed to her personal assistant.

“She also gave me an instruction that the dockets must be copied immediately and the originals must be handed to her personal assistant.”

The request for dockets via letter to Major General Khumalo was never sent because Khumalo indicated the dockets were not with him or under his control, and the letter was subsequently addressed to Lieutenant General Sentumule instead.

“Advocate Johnson testified that we sent the letter requesting the dockets to Major General Khumalo and that he had indicated that the dockets were not with him or were not his. As stated above, the letter was never sent to Major General Khumalo and Advocate Johnson knew that because she told me to shred the letter. Advocate Johnson told me that the letter had been changed and addressed to General Sentumule.”

It is standard procedure to request certified copies of dockets and to leave originals with the owning police station; the requester noted discomfort because he was asked to request the original dockets instead.

“The request for the dockets was yet another matter that did not sit well with me. We usually request certified copies of the dockets and the originals are retained by whomever the request is addressed to... In this instance, I was asked to request for the original dockets.”

There are no checks and balances currently within IDAC's prosecution-led investigation process, which leads to present shortcomings.

“There is no checks and balances ... I am giving evidence today because of the manipulation of section 20 and the prosecution led.”

The SOPs require a multidisciplinary panel including investigation and prosecution to collectively make decisions but this panel is not applied in practice within IDAC.

“The SOPs speak to a panel, a panel that includes investigation, prosecution, and other multidisciplinary... And that panel was supposed to make decisions collectively... It is not applied.”

A general prosecution unit like the OCC has many checks and balances that prevent manipulation, unlike IDAC where such protections are missing.

“...a general prosecution, OCC, OCC is prosecution guided. There are so many checks and balances in place to prevent this very thing we are talking about today ... prevented in that unit because there is checks and balances.”

In IDAC, the SOPs exist but there is no adherence to them, and if they were complied with, current issues would not occur.

“...there is no adherence to that, and if we complied with it and adhered to it, then what is happening now would not happen because we do have written down checks and balances.”

Within the office, gossip about concerns with Advocate Ncube is not effectively addressed, and the head constantly interferes and deviates from the structural basis set out in the SOPs.

“...if I had a problem with Advocate Ncube, I could go and gossip... But I could go and gossip about Advocate Ncube and say Advocate Ncube does not know what she is doing... and then the next meeting Advocate Johnson is at the meeting, and what I said is golden, but the correct way Advocate Ncube is asking for is out the door... the Head constantly would interfere and deviate from that.”

The investigation process for section 27 referrals is supposed to follow strict SOPs, but in practice, there is no strict compliance, though failure to adhere does not necessarily mean the process is irregular as long as it complies in substance.

“The investigation process is supposed to follow a sequence as set out in the SOPs... but even in other section 27 referral... there was no strict compliance with this process... failure to adhere strictly to the SOP does not mean that the process is irregular, as long as it complies in substance.”

Ms Ramsamy and another advocate were given one week to interrogate the evidence in the section 27 referral and found sufficient evidence that it fell within the IDAC mandate, relating to a high-profile individual and serious corruption.

“Myself and the other advocate...when we were given this 27 referral, we were given a week to interrogate the evidence contained in the affidavit referral. We then drafted this, indicating that we had found sufficient evidence that it did fall within the IDAC mandate. Not only under high-profile individual, but also serious corruption.”

The process involved Ms Ramsamy and other advocates setting out the matter, findings and available evidence to inform the decision on their recommendation to proceed.

“Correct.”

Investigator sent an email to Advocate Johnson on 4 December 2024 to inform her that including Ms Ramsamy, staff would be in court on another matter on 6 December 2024 and could not attend a scheduled staff meeting.

“On the morning of 4 December 2024, an investigator working on another case...sent an email to Advocate Johnson...informing her that we, including me, would be in court on another matter that Friday. In other words, he was informing Advocate Johnson that we would not be able to attend the staff meeting.”

The section 27 referral affidavit is supposed to be the A1 complaint statement in the docket.

“My understanding is that the 27 is supposed to be your A1.”

The 27 referral is a complaint statement not currently implemented within IDAC.

“It is a complaint received, but that is my understanding. It is not implemented within IDAC.”

A draft supplementary affidavit must be added to the original complaint (A1) affidavit; you cannot have multiple A1 affidavits.

“But it cannot be a standalone affidavit, and from there, investigations flow in a different direction, or, not different direction, but investigations flow where we are taking no new A1's. But I was told that, this was told to me in 2023. I was shut down with this. When I was dealing with that specific 27 in 2023, I held the same view that the referral affidavit needs to be the A1 in the dockets. I was told that is incorrect and it is not going to happen that way.”

When an investigation has been authorised under section 28(13), a new affidavit is not necessarily required.

“No. With the previous, the 2023, I am just going to refer to it as the 2023 referral, that complainant had come with a letter and a statement, an uncommissioned statement. When the matter progressed before myself and the other prosecutor got involved, the legal representative submitted a very extensive formal affidavit, and that is in the docket. So, we received two different...”

Draft affidavits for witnesses usually come from investigating officers and prosecutors only expect drafts if the investigator indicates the person is a 204 (suspect).

“It is generally in IDAC space at the moment that people or prosecutors get draft affidavits. When most prosecutors preferred draft only if the investigating officer is suggesting that this person is a 204, then it would be a draft. But we generally, because we are prosecution led, if the investigators say he needs to consult with you and he goes to you, I will constantly be updated about what is in the draft.”

Prosecutors are allowed to consult with witnesses under section 28, but a prosecutor must not become a witness in their own matter.

“Because of section 28, prosecutors are allowed to consult with witnesses, right. ... The prosecutor is not allowed to become a witness in their own matter.”

The draft affidavit preparation process involves the prosecutor being present but not assisting in drafting the witness statement directly, to avoid the prosecutor becoming a witness.

“I would not assist. I would be present. The reason I would be present is that I would be able to assist the investigating officers and the witness with regards to the structuring of the affidavit. The prosecutor is not allowed to become a witness in their own matter.”

There was an issue regarding an investigation into a forklift which was not mentioned in the original complaint referral but appeared in the docket and supplementary affidavits.

“One of the issues that I picked up here of the one that was flighted, is there is no mention of a forklift at all, but Mr Raphes will confirm that we received, we just had to trace it, Langlaagte docket for a forklift, and it was in the 27 referral. And the supplementaries that we took was one of them for the forklift and the first three witnesses that were identified were from the forklift documents.”

Mr. Ramsamy concluded the source of information about the R50 million movement from the Crime Intelligence account was the same as the Commissioner's conclusion and shared his reasons for thinking it unlawful to proceed prematurely with the section 28 investigation.

“It is the same conclusion that I came to... I drew that conclusion from the prepaire it in the meantime... The instruction was unlawful to proceed with the 8...”

Mr. Ramsamy reports discomfort and annoyance about whether the person who gave the instruction to proceed with the investigation was going to testify or file an affidavit about receiving the information regarding the R50 million fund movement.

“He said to me, is she going to come and testify that she received the information? Is she going to file an affidavit that she received the information? There was a lot of discomfort and annoyance about this whole instruction.”

Ethics and morals generally guide prosecutors and investigators not to impose narratives on witnesses, but this is not always followed.

“ethics and morals that would guide someone not to do that ... it is not done that way”

Since March 1, 2023, MS Ramsamy personally never attended consultations alone but always with at least two investigating officers or another prosecutor, as a safety net.

“since the 1st of March 2023, have never gone to a consultation without at least two investigating officers or another prosecutor and myself”

There was a discovery of a link between a project authorized under one docket and another, raising concerns about suspects overlapping between cases.

“I had discovered that there is a link from a project that is already authorized to another docket... the link and the suspects are glaring”

In some investigations, an addendum was used to attach new information to an existing section 28(13) without needing a new section 28 authorization.

“I asked her, should we do another new 28? So then I asked, can I not do an addendum and she said it was fine. The addendum was drafted and it was attached and filed to the original 28”

Despite PKTT not being mentioned in the section 27 affidavit, its investigation was not precluded and could be pursued via a section 28(13) addendum.

“even though it is not in the section 27 affidavit... we should still investigate it... I would have still asked to do an addendum”

Ms Ramsamy was specifically instructed not to mention PKTT in her section 28(13) affidavit and to keep details vague.

“I was told specifically not to mention PKTT... I was told keep it vague”

The names of individuals involved in the 2023 section 27 investigation were high-ranking and documents were kept deliberately vague until the investigation was completed to avoid leaks.

“the names in that investigation were so high-ranking... we kept our documents vague... until the investigation was completed... Information leaks”

MS Ramsamy has done multiple section 28(13) affidavits, most of them vague as per instructions or practice.

“I have done multiple 28(13)'s ... most of them are vague as this”

On 5 December 2024, Ms Ramsamy went to Advocate Johnson's office per her instructions where she was given a grey document bag containing a highly sensitive section 27 referral affidavit and a pinkish-purple note with names of suspects handwritten by Advocate Johnson.

“The next morning, the 5th of December 024, at 8 a.m., I went to Advocate Johnson's office per her instructions ... she had a grey document bag with a zip, and she told me that it contained a highly sensitive section 27 referral affidavit ... It also contained a pinkish-purple page from a notepad with the names of people in Advocate Johnson's handwriting. She told me that these are the suspects Chief and I discussed are to be included in the section 28 (13). By Chief, she meant Mr Perumal. Advocate Johnson handed me the bag and gave me the following instructions ... I must take the content of the bag and prepare an application for authorisation of a section 28 (13) investigation ...”

Advocate Johnson instructed Ms Ramsamy not to make copies of the section 27 referral affidavit due to the sensitivity of the matter, but she was allowed to make notes.

“I must not make copies of the 27 referral affidavit. I am allowed to make notes regarding the section 27 referral affidavit. I must not show the section 27 referral affidavit to anyone due to the sensitivity of the matter.”

Ms Ramsamy testified that the pinkish-purple page with the suspects' names was Advocate Johnson's handwriting and that she clearly stated the names Chief and she decided, with Chief referring to Mr Perumal.

“... The page was her handwriting. Her handwriting is very distinctive ... And she had clearly stated to me, these are the names Chief and I decided. But it was her handwriting.”

Ms Ramsamy confirmed she was called by Advocate Johnson during her testimony and that she was asked about the list of suspects.

“When she called you now, as she was testifying here, when she called you, if she did call you, did she call you out to ask about the list? Yes, correct.”

Ms Ramsamy expressed concern about the merits of the application after reading the section 27 affidavit and noted that normally the prosecutor preparing the mandate consideration memo should also prepare the section 28(13) application.

“When I read the section 27 affidavit that Advocate Johnson gave me, I became very concerned about the merits of the application ... in my limited experience, the prosecutors who prepared the consideration of mandate memo ought to be the prosecutors preparing the application for section 28(13) investigation authorisation.”

Ms Ramsamy complied with Advocate Johnson's direct instruction to prepare and submit the section 28(13) investigation application despite her concerns.

“Since the instruction came directly from Advocate Johnson and she had already told me that the decision had been made and that she wanted to approve the section 28(13) then next day, I complied with her instructions.”

Supplementary affidavits by Mr Adams claimed to be true are not accepted as genuine by investigating team members such as Advocate Ramsamy and Investigator Rapetsu who do not know the origin of these documents.

“You have Advocate Ramsamy and Investigator Rapetsu who say they do not know where these documents come from.”

Mr Johnson called a meeting on Friday to obtain requested information including the A1 Statement of Adams, making a formal request at that meeting and briefing Mr Sesoko to follow up.

“I did call a team meeting on Friday in order to also get information that was requested amongst others, the A1 Statement of Adams, that is how I got it. I did make the request there. Advocate Ramsamy was not in that meeting and the project manager undertook that he will find out from her if she has that file. Given that I had done that, I would just send Mr Sesoko a reminder as soon as we have an adjournment to please follow up on that process.”

ADV Johnson identifies members of his investigation team responsible for briefings, including Advocate Ramsamy, Advocate Manilall, Mr Perumal, Mr Padayachee, Mr Mlambo, Mr Charles Eals, and Mr Tlale (project manager).

“It would have been Advocate Ramsamy ... Advocate Manilall ... Mr Perumal, Mr Padayachee, Mr Mlambo, Mr Charles Eals, and Mr Tlale ... as the project manager, from time to time being in those briefings.”

ADV Johnson was never informed by Chief Perumal that statements had been taken from Mr Adams, Mr Rapetsu, and Advocate Ramsamy.

“No. I never came to know about that.”

Investigator Rapetsu and Advocate Ramsamy did not obtain any statement regarding General Madondo about the questionable appointment issues.

“Investigator Rapetsu does not seem to have obtained any statement regarding General Madondo”

There are no allegations related to the PKTT in the official section 27 affidavits of Investigator Rapetsu, Advocate Ramsamy, and Chief Perumal, suggesting a discrepancy in the allegations against PKTT.

“our section 27 does not have any reference to PKTT at all ... I do not know ... it makes no sense”

Advocate Ramsamy made extensive notes from the section 27 and categorized questions for structured investigation follow-up with Mr Adams.

“Advocate Ramsamy had made extensive notes out of the section 27 and having read the inadequate lack of A1s. So she had categorised the questions around groupings of matters to be looked at, aspects to be canvassed with Mr Adams, so that when they went there, it was a structured approach.”

The procedure for obtaining complainant statements involves ensuring that the statement commissioned is genuinely from the witness and not drafted by the investigator.

“The check and balance that we have sought ... is to ensure that it is not one investigator going down to take a statement... It has to be read back to the witness, and when the witness agrees, the statement is signed and commissioned.”

Investigators Advocate Ramsamy, Investigator Rapetsu, and Investigator Perumal went to Cape Town on 6 January 2025 to obtain statements from Mr Adams, gathering around five statements.

“Advocate Ramsamy, Investigator Rapetsu, Investigator Perumal, went to Cape Town on the 6th of January... obtained statements from Mr Adams... I think five in total.”

Statements commissioned by Mr Perumal concerning investigations in Cape Town on 6 January 2025 are considered post-fact fabrications, disavowed by both witnesses and attributed solely to Mansà Robert Rapetsu.

“The statements commissioned by Mr Perumal are a post-fact fabrication. Both witnesses disavow the validity of all these statements... they were all commissioned by Mr Rapetsu.”

Advocates Ramsamy and Investigator Rapetsu took two different statements on the same day, which witnesses say is unlikely as they were together, challenging the legitimacy of the date and signature on some affidavits.

“why would two investigating officers sitting in the same boardroom have taken two different statements on the same day? ... The A1 was not taken in my presence and it could not have been taken on the 6th of January ... Someone was trying to jigga it... it looks like someone was trying to jigga it”

Only four statements were taken on the 6th of January 2025 despite claims of an A1 statement taken that day; the A1 statement was not taken in the presence of Advocate Ramsamy and could not have been taken that day as corroborated by travel and meal observations.

“I can confirm that in my presence, there was only four statements taken ... The A1 was not taken in my presence, and it could not have been taken on the 6th January ... we all travelled together and all meals were done together ... When exactly would Perumal have taken the statements on the 6th if we were together?”

Advocate Joy Hlatshwayo was the lead prosecutor who went to court on the Mokwelematter, while Advocate Ramsamy led the first matter involving General Lushaba and others; they also worked together at court when necessary.

“Advocate Joy Hlatshwayo is the one who went to court on the Mokwelematter. Advocate Ramsamy would have been the one who went to court on the first matter, which was with General Lushaba and others. But they would go to court together...”

Advocate Manilall, Ramsamy, Hlatshwayo, Perumal, Padayachee, Wessels, Mlambo, Eals, and Mbalo were part of the investigation team at different stages.

“It is on my document that it is Manilall, Ramsamy, Hlatshwayo, Perumal, Padayachee, Wessels, Mr Mlambo, Mr Eals, and Mr Mbalo.”