Investigators below senior investigator level are not allowed to gather information prior to authorisation of an investigation under sections 28(13) or 28(1).
“No, from our level, we are not allowed, senior investigators downwards.”
Referred to as: MR RAPHESU · Mr Raphesu · Mr. Raphesu · Mansha Raphesu · Raphesu
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Investigators below senior investigator level are not allowed to gather information prior to authorisation of an investigation under sections 28(13) or 28(1).
“No, from our level, we are not allowed, senior investigators downwards.”
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.”
Mr. Raphesu was shocked by the ID's evidence because it was not entirely correct and appeared false in part.
“I was shocked that the information that she was putting there was not entirely correct.”
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”
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”
Chief Perumal briefed Mr Brian Padayachee before the meeting, surprising Mr Raphesu who expected to receive the briefing as well.
“Chief Perumal indicates that he had already briefed Mr Brian Padayachee. So I was then surprised to say, if we have now been briefed about this now, and he is saying that he has already briefed Mr Padayachee”
During the briefing, Mr Raphesu saw that his name was put as a lead investigator, alongside Deputy Director of Public Prosecution Advocate Manilall and financial investigator Mr Wynand Wessels, but neither Manilall nor Wessels were present at the briefing.
“I saw that my name was put there as a lead investigator ... There was a DPP ... Mr Advocate Manilall, Santos Manilall ... There was a financial investigator ... I think it is Mr Wynand Wessels ... They were not at the briefing”
Mr Raphesu confirmed the matter under discussion related to a briefing that emanated from a member of Parliament, which would have been Mr Adams to confirm.
“the matter emanated from a member of Parliament and that to confirm would have been Mr Adams”
Chief Perumal instructed or tasked Mr Raphesu to locate dockets that bear a case number of Villieria and also indicated the dockets might be locked in a safe in the Station Commander, Commissioner's office at Villieria.
“Chief Perumal was explaining ... He mentioned that he is basically tasking me or giving me instructions to locate the dockets ... The dockets ... bear a case number of Villieria ... dockets might be locked in a safe in the Station Commander, Commissioner's office at Villieria”
Advocate Johnson was said in a briefing to be leading and supervising a certain matter.
“she will be leading thematter”
Mr Raphesu called Mr Sesoko to inform or query if he knew about a new project, hoping to get more clarity on the situation involving meeting allocations and fight for lead roles.
“On the way to Villieria, I decided to phone Mr Sesoko to inform him, or maybe to ask him if he knew about this new project”
Mr. Raphesu was shocked that the Head of Operations did not know about an issue he expected him to know about, reflecting concern over his apparent lack of knowledge.
“Th e w a y h e w a s r e s p o n d i n g , h e w a s n o w a s k i n g m o r e q u e s t i o n s w h e n I w a s s u p p o s e d t o b e a s k i n g h i m t o s a y w h a t i s h a p p e n i n g . S o I w a s a c t u a l l y s h o c k e d t h a t h e d o e s n o t k n o w a n y t h i n g a b o u t t h i s .”
Mr. Raphesu expected the Head of Operations as Head of Investigations to know about matters in his operational space.
“H e i s t h e H e a d o f t h e o p e r a t i o n a n d f r o m w h a t I u n d e r s t o o d t h a t h e s h o u l d k n o w a b o u t w h a t i s i n h i s s p a c e a n d o t h e r t h i n g s .”
Mr. Raphesu drafted an affidavit to clarify collection and chain of custody of dockets relating to the Lushaba matter.
“I w a s r e q u e s t e d t o d r a f t t h i s s t a t e m e n t f o r t h e b a i l , w h e n t h e y w e r e d o i n g t h e b a i l . N o , n o , n o , w h e n t h e y w e r e d e a l i n g w i t h t h e i s s u e o f t h e a r r e s t o f t h e s u s p e c t o n t h e L u s h a b a m a t t e r , t h e r e w a s a n i s s u e r e l a t i n g t o t h e c a s e n u m b e r s , s o I h a d t o d e p o s e t o t h i s a f f i d a v i t j u s t t o i l l u s t r a t e w h i c h d o c k e t s I c o l l e c t e d f r o m t h e o f f i c e o f t h e I n s p e c t o r a t e .”
Mr. Raphesu's draft affidavit was unsigned because it was a draft for his own use; the signed affidavit was submitted in court and disclosed with the docket.
“N o , t h e a f f i d a v i t i s n o t s i g n e d b e c a u s e i t w a s a d r a f t f o r m y s e l f . T h e o n e t h a t I s u b m i t t e d a t c o u r t , I T h o u g h t t h a t i t w a s d i s c l o s e d w i t h t h e d o c k e t .”
Mr. Raphesu voluntarily prepared and gave the second affidavit to his supervisor, Chief Booi, to clarify what happened and dispel issues raised at the Ad Hoc Committee.
“I v o l u n t e e r e d t h e a f f i d a v i t t o m y s u p e r v i s o r a t t h e t i m e w h o w a s C h i e f B o o i . S o I j u s t g a v e t h e a f f i d a v i t e x p l a i n i n g w h a t a c t u a l l y h a p p e n e d b e f o r e t h e y c o u l d a c t u a l l y a s k f o r i t .”
Mr. Raphesu prepared the affidavit to address claims made in Parliament suggesting he did not follow proper procedure regarding letters in the docket process.
“What was said was trying to purport that I did not follow the procedure and I went to people's offices with letters and I did not want to provide them with the letters .”
Mr. Raphesu explained the claims about improper procedure were discussed in a conversation between Advocate Johnson and Honourable Mr. Sauls in relation to affidavits filed by Colonel Phillips and Lieutenant General Jacobs.
“It was a conversation between Advocate Johnson and Honourable Mr Sauls, if I remember, but it was in relation to the affidavit that was filed by Colonel Phillips and Lieutenant General Jacobs.”
Mr. Raphesu was instructed by Chief Perumal to collect dockets urgently because Chief Perumal needed to take them to East London before he moved to Villieria.
“I w a s i n s t r u c t e d a f t e r b r i e f e d b y C h i e f P e r u m a l t o c o l l e c t t h e d o c k e t s , h e s p e c i f i c a l l y t o l d m e t h a t I m u s t g e t t h e s e d o c k e t s b e c a u s e h e w a n t s t o l e a v e w i t h t h e m t o E a s t L o n d o n . H e w a s f l y i n g b a c k t o E a s t L o n d o n o n t h a t F r i d a y .”
Colonel Phillips informed Mr. Raphesu that the dockets were not in Villieria but had been collected by the Hawks and locked up in his General's office, and that dockets could only be released possibly on the Monday morning.
“Already, I have informed Chief Perumal that the dockets were collected, they are not in Villieria, by some Colonel Phillips from the Hawks. ... You cannot get the dockets today. You can only get the dockets possibly on Monday because the dockets were locked up in his General's office.”
Mr. Raphesu collected the original dockets from General Jacob's office on December 9 after the signing of a letter by the ID and its sending to General Senthumule.
“On the 9th I reported to the office of General Jacobs. When I get there, I was informed that the letter has not been signed already or provided already, so I had to wait outside for the office to process the signing of the letter. Some few minutes, about 10 to 15, I was informed that the ID has signed the letter and it has been sent to General Senthumule...I signed for the docket and took them back to the office.”
Mr. Raphesu stated that information about the 'BMW lady' discussed in the meeting came from Chief Perumal, but the name was not mentioned during the meeting and it was just captured that way.
“the issue about the BMW lady, it was coming from Chief Perumal ... the name was not mentioned . It was just the way I captured it”
During a meeting, Chief Perumal asked about a circulating clip, and Mr. Raphesu was tasked to find out from Mr. O'Sullivan if he had opened a case regarding the BMW lady issue or done any work on it.
“during the engagement in the meeting, Chief Perumal asked about a clip that was circulating... they tasked me to go to Mr O’Sullivan to find out if he had opened a case against ... around this issue about the BMW lady ... also to find out if he has conducted or done anything on that matter”
Mr. Raphesu spoke to Mr. O'Sullivan, who provided him with a letter (unclear if from or to the Minister) and a report including CPB details about Brigadier Mokwele; details were sent via email already to Andrea Johnson on 5 December 2025.
“he gave me a letter . I am not sure whether it was the letter to the Minister or from the Minister ... He also provided me with a report ... On that report ... there is something that you call CPB ... So those details , he provided them via email ... that information was sent to Andrea Johnson on the 5th ... of December 2025 already”
The consultation with Mr. Adams in Cape Town was to clarify issues about the dockets, to obtain supplementary affidavits, but did not provide any information beyond what was already in the A1 statements.
“The purpose of the consultation was to provide Mr Adams with an opportunity to clarify issues about the dockets... we obtained supplementary affidavits ... but the purpose ... was not for us to tell him what to tell us. We wanted to get from him what he is going to give us ... he gave us the same thing that was in the A1 here ...”
Mr. Raphesu stated that Mr. Adams indicated he did not have documents to attach to the affidavit, despite efforts to have him provide them for substantiation of allegations.
“when we were busy typing his affidavit ... he indicated that he did not have documents to give us to attach”
Mr. Raphesu acknowledged that the documents shared by Chief Perumal at the meeting on 9 December were likely the same ones referred to by Mr. Fadiel, implying no new documents were disclosed beyond those already seen.
“those would have been the documents that Mr Perumal then shared with you in the meeting of the 9th of December ... there would not have been other documents to disclose ... apart from those that you had already then seen”
The message read that if you disband the PKTT (Police Key Task Team), something to that effect, but the witness could not see the exact sender or recipient.
“it was written there that if you disband the PKTT , something towards that , I cannot remember by head”
MR RAPHESU could not tell who had sent the message nor who it was sent to.
“So you could not tell who had sent the message ? That is correct . No nor could you tell who that message had been sent to ? That is correct , Chair .”
MR RAPHESU stated the messages were attributed to General Mkhwanazi by Mr Adams and forwarded that the message came from the Chief of Staff, Mr Nkabinde.
“You say the messages were attributed to General Mkhwanazi . Was it Mr Adams who attribute the messages to General Mkhwanazi ? That is correct , Chair . And what did he say regarding the forwarding ? What exactly did Mr Adams say ? So regarding the forwarding , he seemed to be saying that he got the message from the Chief of Staff , Mr Nkabinde .”
MR RAPHESU stated that Chief Perumal did the typing of the affidavits and that MR RAPHESU, as lead investigator, commissioned the affidavits without formal discussion or objection from others.
“Chief Perumal was doing the typing , Commissioner . There was no discussion about that , but as a lead investigator on the matter , I just assume that it is me who was supposed to have commissioned the affidavits . There was no objection .”
MR RAPHESU explained Chief Perumal does not want to be named or sign any affidavit but operationally leads everything, so MR RAPHESU assumed commissioning the affidavits was their role as lead.
“Mr Perumal is not a person that will want to put this signature or name in any document . From what I know is , even if you write in your affidavit and you mention him , he is going to fight with you . He does not want to be put on any affidavit . He does not want to be named at anything . But operationally , he leads everything . So I just assume that because I am the lead on this , I have to commission .”
After commissioning the affidavits, MR RAPHESU provided them to Chief Perumal.
“I provided the affidavits to him . That is correct .”
MR RAPHESU and Advocate flew back to Johannesburg together, while Chief Perumal flew back to East London separately after their interviews in Cape Town.
“No , I think the two of us , I Advocate and myself , we flew back and then he flew back to East London .”
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 .”
There was no arrangement made to meet again on the same day with Mr Adams after the meeting where the supplementary affidavit was taken.
“After your meeting where you took the supplementary affidavit , was there an arrangement perhaps to meet again on the same day with Mr Adams , by any one of you , that was made in your presence ? No , Chair , and Commissioners , there was no arrangement .”
MR RAPHESU and others did not have stamps for affidavits and there was no issue raised about the lack of stamps.
“I do not carry stamps , Commissioner . No , we did not have the stamp , Commissioner . No , it is not an issue . No , it was never mentioned .”
MR RAPHESU had a serious concern about an A1 affidavit in the Mokwele matter being purportedly commissioned on 6 January without his presence or knowledge, and Mr Adams never mentioned the contents during his information provision.
“So my concern is , on the day in question , there were only four supplementary affidavits that were obtained , and if that purported A 1 is indicated that was obtained on that day , on the 6th , it was not obtained in my presence . So I am basically also indicating that if there is a possibility that it was obtained on that day , I cannot dispute that , but it was obtained not in my presence . I also indicate that the information that Mr Fadiel Adams provided to us on that day , he never said anything about what was contained in that A 1 , and it could not be that it was obtained at that day , because that information was not readily available at that time .”
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.”
The instruction was to send subpoenas using ID numbers to all banks, despite banks not having those records.
“the instruction was to use the ID number... and then would you then send to all banks? That is correct.”
Mr. Raphesu deliberately put the email subject line "Section what-what" to make the issue stand out and identify it in future as having a problem with the instruction.
“The subject line, I think I did it deliberately, so that it can stand out from the others, just to show that there was a problem with this thing.”
The summons to banks were signed by Advocate Johnson as per procedure, although the correct section reference should have been 28(13) not section 1(a).
“When you look at the background, you indicate... at the time what was authorised would have been a section 28(13)... I noticed that and I accept that it is an error on my part.”
The process for issuing section 28 subpoenas is supposed to go through the project manager to escalate and control, but in this case, it went straight to Advocate Johnson's office without going through the project manager, and there was no project manager involved in this project.
“the process is supposed to move from myself to the project manager, then from the project manager to her office. But it did not move in that way. It went straight to her office this time... No, there was not.”
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 summons about the R 50 million was issued in the absence of an underlying complaint or allegation as required by section 7 referral, therefore misuse of section 28(13) process.
“this summons about the R 50 million in the absence of an underlying complaint or allegation properly that was given to you... In the absence of a complaint properly lodged, this process of a summons is a misuse of the section 8 (13) process? That is correct.”
Mr. Raphesu received some results from banks but was removed from the matter before the process could be completed and analysis provided to the financial investigator.
“we got some results back, but when we received those, usually we give to the financial investigator to analyse... But I was removed before that process could finish.”
Mr. Raphesu made a report on the Lushaba matter and submitted it to Chief Perumal.
“I continued with the investigation on the Lushaba matter. I subsequently produced a report on the findings of the investigation. Then I submitted the report to Chief Perumal.”
Mr. Raphesu refused to work on the Mokwele matter because Mr. Perumal and Mr. Padayachee were meeting witnesses in secret locations and arranging for affidavits he was not aware of; he was later removed from that investigation.
“I refuse to work on that matter... I became aware that Mr Perumal and Mr Padayachee were meeting some of the witnesses... so, I took issue with that... I was removed from the investigation of that case only.”
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.”
There was already an affidavit 204 obtained at the beginning of the Mokwele investigation which Mr. Raphesu was not aware of and he took issue with it.
“there was an affidavit 204 that had already been obtained and that I was not aware of. So I took issue with that also.”
Mr Raphesu does not know the exact date, time, or duration of the call initiating an investigation involving him, as Mr Nkabinde could not recall the date either.
“I did not even know the date, the time, the duration of the call... Mr Nkabinde told them that he cannot remember when the call was made... So as things stand, I do not have the date of the call.”
Mr Raphesu presumes the investigation started on the day he was informed that Mr Mbalowa was the investigating officer.
“I will presume that on that day that I was informed, on the day that I was informed that Mr Mbalowa is the IO, I presume that that was the start.”
Mr Raphesu did not know anything about the investigation related to Mr Nkabinde authorization discussed in the messages until presented with the evidence.
“Did you know anything about this investigation?... No, no, I did not know anything about it.”
Mr Raphesu had no knowledge of the investigation into Mr Nkabinde, and one of the persons involved said the investigation was kept only between three people.
“So, at this stage, you had no knowledge of an investigation into Mr Nkabinde and clearly, one of the people involved is saying that this investigation was kept between the three people.”
Mr Raphesu lodged a grievance on 24th October about being investigated, after repeated unanswered emails regarding the progress of the investigation since 7th February.
“I decided to file a grievance to say I have been investigated from this day... since the 7th of February... on the 24th, I decided to file a grievance... Still today, no one is saying fokol about this thing.”
Since lodging the grievance, Mr Raphesu has heard nothing and the investigation process remains silent with no updates received.
“As we are sitting here, there is nothing. I have not heard anything since then...”
Mr Padayachee accused Mr Raphesu of putting his life in danger by naming him as an investigator, and Mr Raphesu hopes Mr Padayachee is not involved in orchestrating the matter.
“Mr Padayachee was going around the office telling people that I put his life in danger... So I am just putting it... I am hoping it will turn out that he is not part of this because if he is, then I do not know... my belief is that him and Dylan Perumal, they are the ones that orchestrated this thing.”
Mr Raphesu told Mr Nkabinde that Mr Padayachee was an investigator.
“You told Mr Nkabinde that Mr Padayachee was an investigator? That is correct.”
Despite various follow-ups by Mr Raphesu, nothing has come out of the internal investigation process.
“Despite various follow-ups, nothing has since come out of any of these processes.”
Mr Raphesu intends to open a criminal case but delayed opening to not appear as countering the ongoing investigation into him, hoping the Commission will provide assistance with investigators to handle it.
“I am intending to open a criminal case... I did not want it to look like I am countering whatever they were investigating against me... I am hoping that the Commission will also assist by providing investigators to take over that case.”
Mr. Raphesu is presently on duty but with restrictions that prevent him from investigating any matters related to SAPS or the security cluster.
“I am presently on duty, sitting in my corner, jana somewhere.”
Mr. Raphesu stated he cannot investigate any SAPS or security cluster matters including those involving members sitting in the security cluster.
“Page 129 of 131 cannot investigate any matter that has to deal with any SAPS matters, security cluster, that will include all the people that are sitting in the security cluster. I am barred from investigating those cases.”
Mr. Raphesu can proceed with investigations into the Zondo recommendations that are not related to the security sector.
“So you can proceed with all the other investigations into the Zondo recommendations? That is correct.”
Mr. Raphesu acknowledged that Ms. Pooue is included in the security cluster, meaning he cannot investigate matters related to her.
“And CI would be included in the security cluster, so you would not be... That is correct.”
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.”
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.”
Mr Perumal wanted the docket to be collected immediately on the day it was instructed, overriding the letter process, to take it home to Eastern Cape.
“Mr Perumal instructed Mr Raphesu to collect the dockets immediately, he should not wait for the letter, because he, Mr Perumal, wanted to take the dockets home with him to Eastern Cape.”
There was secrecy around the section 27 referral affidavit, which before Mr Perumal's comments, had only been seen by Advocate Johnson, Mr Perumal and Mr Raphesu.
“As far as I was aware, before Mr Perumal's comments at the airport, the only people who had seen the section 27 affidavit Advocate Johnson, Mr Perumal, and Mr Raphesu, because I had shown it to them.”
Mr Padayachee was likely to have seen the original section 27 affidavit during the November Cape Town trip with Mr Perumal and Mr Raphesu due to their presence and the timing of the statement.
“The one that I am speaking about, the one that contains the PKT and the vehicles and the lodges, it would have been improbable that he, impossible, that he would not have seen the original.”
Following day, Mr. Raphesu sent a WhatsApp message raising concerns about stalling summonses until consultation with complainant due to affidavits not constituting a case.
“The following day, 11 December 2024, Mr Raphesu sent me a WhatsApp message to raise the same concerns I had. If forwarded this message to Advocate Johnson. Essentially, Mr Raphesu suggested that we stall or park the summonses until we had consulted with the complainant because his affidavits simply did not set out a case.”
The process of requesting and collecting dockets was complicated by internal office commotion and changes in official letter addressees, resulting in Advocate Johnson instructing shredding and changing letters instead of sending original requests to Major General Khumalo or Lieutenant General Jacobs.
“There was a lot of commotion on that day... I had to change the letter request from Major General Khumalo to Lieutenant General Jacobs... Her response was that I must shred the letter because it was not going to Lieutenant General Jacobs. She said she had written to Divisional Commissioner Detective Services, Lieutenant General Sentumule... Advocate Johnson told me to ask Mr Raphesu to call Colonel Phillips and ask if Lieutenant General Sentumule had asked Colonel Phillips to hand the dockets over.”
Mr. Ramsamy distanced himself from the section 28's documents because he had advised Mr. Raphesu who had received instructions from the Head of office, and felt explicating the section 28's in court would be difficult.
“I advised Mr Raphesu, he has received his instructions from the ID. I had addressed his concerns. He had received instructions from the Head of office and I then distanced myself from these 28's because how were you going to explain this at court and who was going to explain it at”
Mr Raphesu's supplementary affidavit does not mention PKTT, despite it being the basis of an investigation under section 27.
“Mr Raphesu supplementary affidavit that speaks about the PKTT when the section 27 ... says nothing about the PKTT”