Witness I

Witness I stayed at Mr Matlala's family property in Mamelodi for approximately two years from 2023.

“in 2023, I stayed at Mr Matlala's family property in Mamelodi for a period of approximately two years”

In September 2023, Witness I was attacked by four men at his residence in Mamelodi and seriously injured.

“On or about September 2023, there was an attempt on my life. I was residing in Mamelodi when a group of four men attacked me at my residence...hit my head with a metal object, resulting in a serious head injury...breaking my left hand and several fingers...They then stole my state-issued firearm and left me for dead”

State-issued firearm stolen during attack was later recovered by TO MS members.

“The state firearm was later recovered by TO MS members”

Captain Zungu warned Witness I the attackers may return and suggested temporary relocation and arranged a house for Witness I, which belonged to Mr Matlala.

“Captain Zungu warned that I was injured and that the group may come back and finish the job. He then suggested that I relocate temporarily and that he will arrange a house for me...property belonged to Mr Matlala”

Witness I did not meet or communicate directly with Mr Matlala during his stay at the property, only via Captain Zungu and Brigadier Mokoena later.

“During my stay, I did not meet or talk to Mr Matlala...I have had no direct communication with Mr Matlala until I met him with Captain Zungu and Brigadier Mokoena”

Witness I received warnings that senior members were unhappy with his testimony and that there was a plan to disclose his stay at Mr Matlala's house to discredit him.

“After my testimony, I received a number of calls warning me that the seniors are not happy with my testimony...there is a plan to disclose my stay at Mr Matlala's house as a way of discrediting me...I considered it a threat”

The DPCI TO MS mandate has been dismantled under General Mbotho and Brigadier Mokoena, limiting members' tactical equipment access and overtime compensation, resulting in resignations or transfers.

“I have been informed by members that, as threatened by General Mbotho, TO MS's mandate has been completely dismantled...members forced to surrender tactical equipment such as rifles...not allowed for immediate response...members who work overtime are not compensated...dedicated members have either resigned or took transfers out of TO MS”

In 2021, a truck carrying a boat containing one tonne of cocaine was seized during a bust operation involving SANEB and other office members at the scene.

“The 2021, it was a truck carrying a boat, which boat had one tonne of Cocaine.”

WITNESS I was called to the scene by a Commander and found members of SANEB Head Office and WITNESS I's office carrying out the seizure of cocaine from a truck carrying a boat.

“I was called in by my Commander to come to the scene. When I arrived there, I found members of SANEB Head Office and members of my office with a truck carrying a boat by the side. And they were taking out the contents from the boat, putting them on the ground, which was ultimately found to be Cocaine, which amounted to one tonne.”

WITNESS I was requested to bring the SAP13 book from their office to the Pretoria West Training College as part of the 2021 cocaine seizure operation.

“I was requested to go to office, obtain SAP13 page 11 of 135 book from my office, and bring it to Pretoria West Training College, where the seized Cocaine was booked at for safety.”

In 2021, as Team Leader of SANEB, WITNESS I's members received a tip-off about a person transporting drugs to Pretoria; the team intercepted the person on N4 and found crystal meth worth about R600,000 in the vehicle.

“In 2021, as a Team Leader of SANEB, my members received a tip-off of a person who will be transporting drugs, bringing them to Pretoria. The SANEB team of Pretoria Organised Crime activated the information and intercepted the said person on N4. ... the vehicle contents were checked and Crystal Meth was found inside this vehicle worth about R600000.”

WITNESS I led the SANEB Pretoria Organised Crime team during the 2021 crystal meth interception operation.

“I was leading the team on that operation.”

WITNESS I is familiar with the relevant framework for protocols on search, seizure, handling, processing, and disposal of illicit drugs and the National Instruction on Crime Scene Management.

“So you are familiar with the relevant framework, including the protocol on search, seizure, handling, processing, and disposal of illicit drugs, as well as the National Instruction on Crime Scene Management? Yes.”

After the Aeroton operation and before transfer to TOMS, WITNESS I was not involved in another operation.

“After the Aeroton one, while you were still with SANEB, before you were transferred to TOMS, there was not another operation where you were involved in? No, not that I can recall, Commissioner.”

WITNESS I informed other SAPS units with whom he was familiar when they encountered drug-related scenes where they would call WITNESS I for assistance.

“It is something I informed other units within SAPS, other unit members, whom I know.”

Witness I confirms they initially thought the tip-off related to the Masoma inquiry concerned drugs covered by that inquiry, but later realized it was a completely different cocaine drug from Brazil, unrelated to the inquiry.

“by then I did not know how it came . That came about later on .”

Witness I states they were briefed only by Warrant Officer Phakula upon arriving at the scene where cocaine bags were found, and did not discuss with other officers who had arrived earlier (DPCI Germiston and Johannesburg).

“I only spoke with Phakula , the Warrant , and it is when the scene I withdrew after the General came in from Intelligence . Speaking with Mashaba , it was after, when the intention to arrest them was brought .”

Counsel Adv Baloyi SC questions why Witness I insisted the cocaine drug scene was part of the same inquiry given the briefing and information about a different drug and origin, implying Witness I ignored the discrepancy.

“Yo u a r e b e i n g , y o u a r e g i v e n t h e s t o r y. ... How do you still insist that this has anything to do with your inquiry number without even asking what is in there ?”

Witness I admits they did not discuss the drugs with all officers at the scene but only with Warrant Officer Phakula initially and spoke to Mashaba later when the intention to arrest was communicated.

“No , I was not , Commissioner, maybe I do not know the understanding . I did not discuss with all four of them . As I arrived , I only spoke with Phakula , the Warrant , and it is when the scene I withdrew after the General came in from Intelligence . Speaking with Mashaba , it was after , when the intention to arrest them was brought .”

Counsel Adv Baloyi SC argues it would be irrational for Witness I not to have asked basic questions about the cocaine drug scene if related to their inquiry, given the briefing received from the driver and others explaining the transport and origin details.

“I am not accepting that you did not ask those questions that would have informed you that maybe this is not in fact my inquiry number and I should stay out of it .”

Witness I confirms having seen the 2020 statement referred to by Adv Khumalo SC before attending Aeroton in July 2021 and acknowledges it relates to 'Nyaope'.

“It is a 2020 statement , Commissioner. ... Yes . ... So you knew that it related to Nyaope ? Yes .”

Witness I agrees it is a fair observation that Masoma does not appear as investigating officer in the Aeroton investigation diary, suggesting he was not the appointed investigator for that inquiry.

“Yes , Commissioner ?”

Witness I was shown a WhatsApp message claiming to be from a source in Durban but was not told the source identity.

“He showed me a WhatsApp message, and I read through the message, and I asked the message comes from whom. He said my source in Durban.”

Witness I did report before leaving the scene but the content was incorrect or misrepresented what he was going to do.

“you did report, but what you reported was incorrect or you misrepresented what you were going to do.”

Witness I initially told Colonel Seobe he had a family thing to attend, not that he was going to High Court.

“W I T N E S S I”

Witness I denied any knowledge about specific operations and was not informed by members including Masoma about operational duties.

“My response to that was that I know nothing about such operation and that both members did not inform me of any operational duties that they will be part of or information that they had been working on, on the day in question.”

Witness I was going to meet a representative at Johannesburg High Court related to custody issues, not to attend court personally.

“I was supposed to go meet someone who will represent me on the custody issue...I was not going to court.”

Witness I was reluctant to inform her Commanding Officer out of fear that information would be compromised at higher levels, possibly causing tip-offs.

“you had a fear or you were scared of the information being compromised at a higher level... initially you said conflict of interest or that if info gets out, people maybe tipped off.”

Witness I has no experience of her Commanding Officer compromising investigations but claims reporting up from Commanding Officer to Provincial level is where compromises occur.

“No, not my Commanding Officer. When I go to my Commanding Officer, he needs to report to Provincial higher up. And where he is reporting higher up, it is where it is being compromised.”

Witness I states that planned operations often fail because information is leaked when reporting before execution, so their stance is to execute the operation and report only after arrest.

“planned operations... ultimately fail because it has been reported beforehand... That is why my stance mostly is that we execute the operation. Once arrest has been made, it is report then when we may have been successful.”

Witness I left Pretoria with Masoma to a scene in Aeroton and was going to verify information, not to execute an operation.

“when we left, it was not for execution. It was to check and verify. It was like it was information-checking... we arrived... it is the same quantity as Masoma received the message.”

Witness I asserts that although arriving to verify, a claim was made that the scene and drugs were known, and this assertion was without verification but based on what was told to Witness I.

“you speak only to Phakula. Then the next thing you say is, this is my scene... you have not verified that there is drugs... It is just black bags on the back of a van... You have not verified anything. So we are back at... you knew exactly what it was... That is why you were able to assert yourself and say this is my scene.”

Witness I states the utility of reporting to Commanding Officer before operations is so the officer can know the whereabouts of the member and account for them.

“So they could know whereabouts of the member... so they could account where the member is.”

Witness I acknowledges difficulties when officers go on operations or verification exercises without telling their Commanding Officers.

“Yes.”

Witness I did not inform their immediate superior, Colonel Seobe (acting Unit Commander), that they were following a lead and would report back later; instead, they told her they were going to Johannesburg High Court.

“Why did you not say to Colonel Seobe ... I am now following on a lead and I will come back to report to you once I know what is going on?”

Witness I's position was they would report to their superior once they knew everything that had happened and where they had been asked to go.

“I believe by that status my take was that I would report once I know everything what has happened, when I get where I have been asked to come.”

Witness I admits they should have told Colonel Seobe they were following a lead and would report back.

“I should have done that, Commissioner.”

Witness I inconsistently stated they needed to verify the quantity of drugs on site despite earlier claiming to know the quantity before arrival and to believe it was part of their inquiry number.

“You said that you needed to verify because you then confirmed the quantity of the drugs once you were there ... This is different from what you said in your statement ... you knew the quantity before ...”

Witness I states they were informed of the quantity but needed to confirm on arrival that what they were told was correct.

“No, I was informed of the quantity and I needed to confirm when I get there that what I was told is right, it is as it is.”

Witness I did not speak to DPCI members from Germiston and Johannesburg upon arrival because they first needed a briefing to understand the situation before liaising with colleagues.

“The people who called me to the scene, I had to get a briefing first and after then I will relate with my other colleagues of Johannesburg and Germiston.”

Witness I knew when arriving that DPCI members from Germiston and Johannesburg were at the scene but chose to first speak to Warrant Officer Phakula instead of DPCI members, despite Phakula being the person they should speak to per procedure.

“You saw them when you arrived that your colleagues are there ... so you knew ... but you went to Phakula ...”

Witness I deliberately misled their superior by telling them they were going to Johannesburg High Court when they instead were going to an operation scene to legitimize an unlawful operation and conceal their true purpose.

“You made a decision not to inform the Acting Unit Commander that you are going to Aeroton because ... you are hiding from her for wrong reasons ... you told her that you had gone to the High Court ... You arrive at the scene ... you do not speak to DPCI who have jurisdiction ... you speak to Phakula ... this conduct up to this point is calculated conduct ... to legitimise an unlawful operation ...”

Witness I refuses to comment on the accusation that their conduct to legitimize the unlawful operation was calculated.

“I will not comment, Commissioner.”

ADV Khumalo accuses Witness I of using the inquiry number to legitimise an unlawful operation by Maganean, Phakula, and Mashaba which was interrupted by SAPS members dispatched by 10111.

“Your presence there and your use of this 2020 inquiry number was to legitimise what was otherwise an unlawful operation ... to steal the drugs.”

ADV Khumalo says the unlawful operation was interrupted by Booysen's SAPS and other units including Flying Squad and Officer Rikhoitso, yet Witness I did not inform their superiors or speak to all officers on scene but only later spoke with Colonel J. C.

“When you arrived at the scene, you found DPCI who have jurisdictional control ... why did you not speak to them ... others including Booysens police, Flying Squad, Officer Rikhoitso ... you spoke with Colonel J C afterwards ... why did you not talk to all the other officers on scene?”

Major General Khan's statement about his engagement with Witness I at the crime scene is a lie; Witness I denies that interaction happened.

“this never happened. It is a lie, paragraph 8, by the General”

Witness I states that he never spoke with General Khan the whole day and that the report by General Khan of interactions is false.

“I never spoke with him for the day”

General Khan allegedly called Witness I at 11:55 to ask if he had reported to him and if there was a narcotic investigation, and stated he intended to arrest him for defeating the course of justice.

“he received a call from Major General Khan, asking if you had reported to him, and whether you had a narcotic investigation… he was going to arrest you for defeating the course of justice”

Witness I denies having any conversation with General Khan and says all people at the scene confirm no interaction occurred.

“I still maintain I never had a conversation with General Khan and all the people on the scene could confirm to that effect”

Witness I disputes that Major General Khan contacted him and spoke with him regarding the scene.

“The fact that he never contacted me and he alleged he spoke with me, that is what I do not agree with.”

Witness I denied having learned from Sergeant Phakulatha that there was a discrepancy in the quantities of exhibits collected at the scene, which was later disproved by evidence presented to the Commission showing the actual bricks were more than initially recorded by 15 blocks.

“You indicate that you learned from Sergeant Phakulatha that the quantities of exhibits collected from the scene were different and instead the block of bricks were less by a hundred. Evidence has been presented to this Commission that that is untrue. And in fact, what happened was that there were more bricks that ultimately were reported to FSL than what was recorded on the scene and the difference was 15 blocks.”

Witness I agrees that indicting Generals Kadwa and Khan for acting above the law was unfair criticism after new evidence was presented.

“do you accept that the indictment that you launched on Generals Kadwa and Khan, whereby you say on the day in question it is evident that those individuals were acting above the law, that that is an unfair criticism on the two Generals? Yes, having learned what now is presented, yes, I agree, Commissioner.”

Witness I after new information no longer says that Generals Khan and Kadwa defeated the ends of justice, accepting there was no such defeating.

“So you no longer say they defeated the ends of justice? Yes.”

The witness denies having any direct contact or relationship with Mr Matlala and states that Captain Zungu was the one who informed him about the meeting facilitated by Mr Matlala.

“No I would say it is a lie because I never spoke with Mr Matlala, I only spoke with Captain Zungu for the day, even my reason going there.”

Captain Zungu told the witness that the meeting was facilitated or arranged by Mr Matlala, which the witness accepted in his statement.

“Yes ... it is in relation to me being a witness on General Khan's matter, it entails General Khan ... Yes.”

The witness alleges the transcripts of the recordings have been contaminated and do not reflect the true events; denies receiving any cash payment related to the meeting or case.

“I never received any cash. I was awaiting the CI guy and Brown to contact me to bring the bag as they promised so I could arrest them, but the facts of those, they do not reflect here. That is why I say the recording was contaminated, only what is displayed it is what benefits them.”

The witness was arranged by Captain Zungu to live in Matlala's family house for about two years.

“Yes.”

According to Mr Mogotsi's evidence, the discussion about needing cash was in relation to the witness's meeting to assist, and Mr Matlala arranged to give the cash through Khan if the information was worth it.

“"I think he needs cash." And ... Dlamini says: "Okay, arrange with Khan to give him cash if the information he has is worth it."”

The witness denies receiving any cash payment in relation to General Khan's case despite transcripts suggesting otherwise, asserting that recordings have been tampered to favor others.

“No. Commissioner, earlier on you remember I mention the fact that the transcripts of the recording have been contaminated ... I never received any cash.”

Witness I admits that two women attempted to entice them to change their testimony in a disciplinary hearing to assist Major General Khan in winning the case.

“the two women came to you to entice you to change your testimony”

Witness I contends that some things are missing from the transcript and insists the recording has been contaminated or manipulated and selectively edited.

“I believe the recording has been contaminated or manipulated to look as it is because it is not fully, everything else is indicated there. It seems like there is a selective things which have been put here”

After the meeting where the attempt to bribe was made, a proper inquiry was registered to entrap Witness I, suggesting an effort to undertake a legitimate operation.

“a proper enquiry is then registered to entrap you and that suggests that they were trying to undertake a legitimate operation”

Witness I did not take any action after the attempt to bribe, nor register any enquiry.

“you do not do anything, nor do you register an enquiry”

Witness I acknowledges that no supporting affidavit or corroborating documents have been filed to support their version of events and says this is because it was never asked for.

“there is no affidavit or anything that he has filed to corroborate your version”

Witness I explains that verbal authorizations for operations were routinely given over the phone and paperwork followed afterward.

“I did get authorization verbally. Telephonically I explained everything. They say once the operation is completed, do paperwork. It has happened”

Witness I intended to initiate a telephonic request for authorization after a meeting that was agreed upon but which never happened because the other party never came back to them.

“I was going to initiate that telephonic request for authorization and once received, I execute it ... But they never came back to me”

Witness I disputes the improbability of their version of events asserted by counsel and insists their account is accurate despite lack of external supporting evidence.

“I will dispute that to the Commissioner. I will dispute that”

In December 2024, Matala referred Brown Mogotsi to a high-ranking police officer known to Witness I, who subsequently met with him, and the officer shared information about an intention to graft a negative finding in respect of the disciplinary hearing against Major General Khan.

“In December 2024, Matala referred me to a high-ranking police officer and I subsequently met him. I knew him as I had conducted an operation with him in the past. He shared information with me of the intention to graft a negative finding in respect of the disciplinary hearing against Major General Khan.”

Witness I does not dispute that Brown Mogotsi said it was Matala who referred him to Witness I and that he subsequently met Witness I.

“No .”

Brown Mogotsi stated that Witness I wanted money relating to a bag, possibly implying cash but did not explicitly say a bag of cash.

“He spoke about something. He said yes, he was talking about a bag. Maybe he implied cash, but he never said a bag of cash.”

Brown Mogotsi said he had to go back to Matala because the person Matala had referred him to was asking for cash, and that Witness I was asking for cash, which led to the discussion about Major General Khan.

“the person Matala had referred him to was asking for cash. Therefore, he needed to go back to Matala to tell him that you were asking for cash. And that is how it came about that discussion about Khan.”

Witness I denies that Witness I was asking for cash and suggests instead that Brown Mogotsi wanted cash himself, alleging that what was asked was to change the statement to facilitate a promotion and a bag (possibly metaphorical). Witness I says Mogotsi put him in a bad light intentionally.

“I will dispute that. Maybe Mr Mogotsi wanted cash himself, because me, what was asked was that I change the statement, they will facilitate I get a promotion and a bag. Maybe Mr Mogotsi, when he related to other people, he puts me in a picture which he is the one who is doing that, because...”

Witness I asserts that in a meeting it was Brown Mogotsi and another CI guy who offered him a bag and a promotional post.

“On the meeting, it is him and the CI guy who offered me a bag and a promotional post.”

Witness I holds a national diploma in accounting from the University of Johannesburg and completed various police training courses.

“I have a national diploma in accounting from the University of Johannesburg and did courses within SAPS, Introductory Police Training, Basic Crime Investigative Practice, Serious and Violent Crimes, SVC, Street Survival, Legal Principles, Vehicle Crime Investigators Course, Discipline Management Processes Learning Programme, Detective Commanders Learning Programme”

Witness I began employment in law enforcement in 2002 with the Directorate of Special Operations (DSO) known as the Scorpions, and remained until the DSO was disbanded in 2009.

“I began my employment in law enforcement with the Directorate of Special Operations, DSO, commonly known as Scorpions in 2002, and remained there as an Investigator until 2009 when DSO was disbanded”

Witness I was transferred to the Directorate for Priority Crime Investigation (DPCI) in 2009, based at Serious Organised Crime Unit, and by 2021 was Team Leader for the South African Narcotics Enforcement Bureau (SANEB).

“Members were transferred to the Directorate for Priority Crime Investigation, DPCI, in 2009, and I was based at Serious Organised Crime Unit. In 2021, I was Team Leader for South African Narcotics Enforcement Bureau, SANEB, a specialised unit within the SAPS”

Witness I accepted a transfer in 2023 to Tactical Operations Management Section (TOMS) under Brigadier Smith and later Brigadier Mokoena, with both reporting to Lieutenant General Mboto.

“In 2023, I accepted a transfer to Tactical Operations Management Section, TOMS, under the command of Brigadier Smith then, but now under command of Brigadier Mokoena, both Brigadiers reporting to Lieutenant General Mboto”

Witness I is presently a Subsection Commander at TOMS, with duties including investigations, extraditions, surveillance, and operational leadership, reporting to National Head and Divisional Commissioner of DPCI.

“I am presently a Subsection Commander at TOMS, and my duties include open, inspect, and close enquiries... conduct surveillance observation and monitoring on armed robberies... attend management meetings within the unit and also lead members in meetings with third parties and other role players, command and control of members on all operational tasking”

Witness I was Team Leader at SANEB in 2001, leading a team investigating drug-related matters such as smuggling, dealing and trafficking.

“In 2001 when you were the Team Leader of SANEB, what were your duties then? It was leading a team in investigating drug-related matters, smuggling and dealing and trafficking of drugs within the country”

Witness I's SANEB team comprised about four to five members and operated territorially in Gauteng province.

“I think there were four to five members. It is Gauteng. The entire Gauteng? Yes.”

Section 252A operation is described by Witness I as an entrapment application.

“What is a section 252A operation? It is an entrapment application. Entrapment.”

In 2020 around August, Sergeant Masoma opened an inquiry on a suspect from Zambezi, Pretoria North for alleged narcotics dealing and transporting; the inquiry file was opened within the unit for preliminary investigation and evidence gathering.

“In 2020, around August, Sergeant Masoma opened an inquiry on an individual from Zambezi, Pretoria North, who was alleged to be dealing and transporting narcotics. An inquiry file is opened within the unit to do preliminary investigation and gather evidence.”

On 9 July 2020, Sergeant Masoma received a tip-off about 23 bags of drugs en route from KwaZulu-Natal, and Witness I requested more details before acting on the tip-off.

“On 9 July 2020, at around 7 a.m., Sergeant Masoma notified me that he had received a tip-off the previous night about 23 bags of drugs en route from KwaZulu-Natal. I asked Sergeant Masoma to obtain more details... before we could act on the tip-off.”

Witness I received a tip-off related to the inquiry from a source in KwaZulu-Natal on 6 August 2020.

“the message is in relation to the inquiry 6/8/2020”

On 9 July 2021, while on official duty in Pretoria, Witness I received a call from Sergeant Phakula of the K-9 unit about a truck suspected of transporting 23 bags of drugs from Durban to Johannesburg linked to the inquiry.

“on 9 July 2021, whilst still on official duty at my office in Pretoria, I received a telephone call from Sergeant Phakula of K-9 Unit ... truck suspected of transporting 23 bags of drugs in the Johannesburg area ... truck in question was also from Durban”

The 23 bags of suspected drugs were linked to the tip-off about the Pretoria inquiry from 6 August 2020, and Sergeant Masoma had also informed the witness the same morning.

“information about the 23 bags of suspected drugs coincided with the information Sergeant Masoma had informed me of the same morning, regarding the tip-off relating to Pretoria inquiry 6/8/2020”

Witness I attended the scene of the drug find with Sergeant Masoma and found the suspect driver already under arrest and drugs were kept in a police bakkie without being booked at Booysens Police Station.

“I immediately went to Johannesburg with Sergeant Masoma from my office ... The driver of the truck transporting the drugs was identified ... already under arrest ... drug bags were kept on police bakkie ... truck containing the drugs was never booked at Booysens Police Station SAP13, but kept at station until it was collected by owner”

Major General Khan from the Intelligence Division took over the drug scene and instructed officers to detain those who located the truck; one suspect driver was released from custody by Major General Khan.

“General from Intelligence Division, later known to me as Major General Khan ... issuing instructions that those who located the truck containing drugs should be detained ... driver who was already detained by the members was released from custody by Major General Khan”

Major General Kadwa told Witness I that Germiston DPCI will deal with the scene and refused to discuss the inquiry file, instead directing the witness to Brigadier Sekgobela.

“Major General Kadwa told me that Germiston DPCI will deal with the scene ... he essentially avoided talking to me by evoking the SAPS chain of command and instructed me to rather address Brigadier Sekgobela”

Colonel JC Maluleke from DPCI Organised Crime Johannesburg advised Witness I to leave things alone and submit a statement explaining attendance at the scene, threatening arrest if statements are not made.

“Colonel JC Maluleke from DPCI Organised Crime Johannesburg advised me to leave things alone and that me and my members should just provide our statement ... Colonel JC Maluleke said if we do not make such statements, the Generals will arrest us”

Witness I called Lieutenant General Lebeya to report the scene situation, but feedback promised by Lebeya was never given.

“I immediately called the Office of the National Head, Lieutenant General Lebeya, for me to come and have a meeting with him on what transpired ... Lieutenant General Lebeya promised to look on the matter and give me feedback, which was never done”

Witness I is the Team Leader of SANEB and members of several SAPS units inform him about drug-related scenes to provide alerts or ask for engagement.

“I am Team Leader of SANEB, and if they hear or have a scenario where drugs-related things are there, they should inform me.”

Witness I requested a narcotics dog from K-9 unit to confirm if suspected drugs at a scene are really drugs, emphasizing the need for certainty.

“If they say there are drugs, we need to confirm for sure if they are really drugs ... I requested a narcotics dog.”

Witness I states that an inquiry is opened on CAS system with a file indicating alleged criminality, assigned to a member to run and conduct preliminary investigation and get evidential material, supervised by commanders.

“The inquiry is opened on the CAS system, and a file is opened with the alleged criminality being indicated... it is given to a member to run and start conducting preliminary investigations... This process is monitored by your Commanders.”

Witness I would report operational tip-offs to the Unit Commander, who was Colonel Bok at the relevant time, but also to other two full Colonels.

“If you had to inform someone... to the Unit Commander, Colonel Bok ... Not only him. Then there were three full Colonels.”

Witness I received a call about a truck suspected to have drugs and intended to verify and confirm the information on the scene with Masoma.

“I received a call that there is a truck suspected to be having drugs. My intention and reason I went there with Masoma was to verify the info I received and check if it is true and correct.”

Witness I learned from Sergeant Phakula of K-9 that the number of drugs restored at Pretoria West College was no longer the same, missing over 100 bricks from the initial quantity collected.

“I learned that the number was no longer the same ... the block of bricks was less by over 100 in number. I learned from Phakula of K-9.”

Witness was directed to go to a meeting at the Houghton Hotel accompanied by Warrant Officer Mahlaba, who works under the witness at TOMS, for assistance with a state vehicle.

“I went to the meeting venue with Warrant Officer Mahlaba who works under me at TOMS. And taking Warrant Officer Mahlaba with me was in respect of assistance with state vehicle, as I was not in position of any state vehicle and he was, but Warrant Officer Mahlaba stayed in the car when we got to the hotel.”

The proposed bribery involving a bag was never reported as it would have reached the ears of targeted people and reporting would have been done post arrest to avoid obstruction from seniors. The bribe never materialized and there was no further discussion about it.

“The above was never reported as it would get to ears of the targeted people and reporting would have been done after arrest to evade blocking or obstruction from seniors. They never brought the bag and never had any further discussion about the bag.”

In January 2025, Major General Khumalo, District Commissioner of KZN, informed Witness I that he would be receiving a subpoena.

“During January 2025, I was phoned by Major General Khumalo, District Commissioner of KZN, informing me that I will be receiving a subpoena to come”

Statements from witnesses given between 17 February 2025 and 21 February 2025 were used as evidence in the disciplinary hearing against Major General Khan.

“All members who were witnesses led evidence from 17 February 2025 to 21 February 2025 as planned and arranged with General Khumalo. Statements made which depict what transpired on the said day were used as evidence in the disciplinary hearing.”

Lieutenant General Mkhwanazi acquitted Major General Khan for reasons unclear to Witness I due to unclear and contradictory witness evidence and insufficient evidence.

“Around end of February 2025, I found out that Lieutenant General Mkhwanazi had acquitted Major General Khan for reasons unclear to me. ... witnesses were not clear and contradicted each other. They also noted that the evidence was not sufficient.”

Mr Vusi Matlala is alleged to use SAPS to eliminate his opposition, which is unknown to Witness I who never participated in operations involving him.

“I have heard of the allegations that Mr Vusi Matlala is using SAPS to eliminate his opposition. This is unknown to me as I never had an operation or been involved in an operation where TO MS was used by any individual.”

The John Wick scene referred to a police operation where the suspect was fatally wounded, not an arrest.

“No. The suspect on that scene was fatally wounded, Commissioner.”

Brigadier Mokoena refused Witness I's request to meet the source involved in the John Wick scene and claimed the case was top secret between him, National Head General Lebeya and the source; Witness I and Captain Zungu were being used in an extortion attempt against Mr Matlala.

“At the meeting, I asked Brigadier Mokoena if we could have a meeting with the source and get more details and facts. Brigadier Mokoena refused the request. He said I cannot consult with the source as it is a high-profile matter of top secret dealt with between him, National Head General Lebeya and source. I noted that this is a non-existent as by then Brigadier Mokoena did not have top secret clearance and observed me and Zungu are just being used in an attempt to extort money from Mr Matlala.”

Witness I reported the matter of alleged corruption and interference to IPID after a year but nothing was done; the case docket remains under investigation with no progress.

“After a year I reported the matter to IPID and nothing was done by IPID in the sense that when I asked status, they said the same docket is still under investigation and there is nothing they could do”

Witness I wrote to Ian Cameron, Chairperson of the Portfolio Committee of Police in Parliament, about the conduct of General Mbotho but did not receive a substantive response.

“Around 025, I wrote an email to Ian Cameron, the Chairperson of the Portfolio Committee of Police in Parliament about the conduct of General Mbotho ... I requested Mr Ian Cameron to have a meeting with me and he responded he cannot secure an appointment without knowing the discussion title. Since then no further contact occurred”

The person involved in the case is taking mining rights from lawful owners and behaving like a Zama-Zama kingpin because the mining plans do not belong to him and he hijacked or took them by force.

“We could label it either way, Commissioner, because the person takes away mining rights from lawful owners and mines on those mines. So the person will be behaving like a Zama-Zama because the plans where he will be mining does not belong to him. He is the one which she hijacked or took by force.”

The arrest in their operation related to the discussed case was in September 2024, which Mr Mogotsi saying in December-January referred to another matter, not theirs.

“No, Commissioner. Our operation, the arrest was in September 2024. Maybe he was referring to another matter, not ours.”

The witness opened an inquiry number when all allegations were brought to their office so that members can start doing preliminary investigation.

“Commissioner, when allegations were brought to our office, I opened an inquiry number so members can start doing preliminary investigation on.”

After the inquiry was opened, the suspects shot at public members causing the office to have to react and act on it.

“I will say we were fortunate on this matter that not long after the inquiry has been opened, the suspects shot at public members and we had to react and act on it.”

The complainants named in the inquiry are against the suspect who takes mining rights unlawfully.

“They are against the suspect who takes mining rights.”

Application by Witness I for his evidence to be heard partially in camera on 9 June 2026 was granted by agreement between the parties.

“the application by Witness I for his evidence to be heard partially in camera on 9 June 2026 is granted”

The testimony of Witness I will be heard publicly via audiolink but his face or visual features will be concealed to protect his identity.

“The testimony of Witness I will be heard publicly via audiolink and his face or visual features will be concealed”

Members of the media and authorized persons are prohibited from publishing or broadcasting any material that may reveal or tend to reveal the identity of Witness I.

“Members of the media and any persons granted access to the proceedings are prohibited from publishing, broadcasting, disseminating or otherwise placing in the public domain any image, photograph, video footage or other visual material that may reveal or tend to reveal the identity of Witness I”