What the outspoken ANC MP has to answer to

COUNT ONE:

On or about the following dates:

7 July 2017 at 20h5O on

●

Facebook; and/or

18 July 2017 in a speech

● delivered in Johannesburg; and/or

20 July 2017 at l5h03 on

●

Facebook; and/or

20 July 2017 at l5h43 on

●

Facebook; and/or

On various other dates in the

● period between 6 July 2017 and 24 July 2017 on Facebook, you made various statements, inter alia, as set out in Annexures A,B,C and 0 respectively.

These were public statements; alternatively you knew or reasonably ought to have known that they would become public; and/or

These statements individually and/or collectively breached one or more, or all of the abovestated rules of the ANC constitution; and/or

The said statements were made outside the structures of the organisation.

Indeed, you refused and/or failed to use the opportunity provided by the national policy conference, which you attended, to legitimately raise your views on the platform provided.

Instead, you preferred to use public media to do so; and/or

A significant portion of your statements constitute a public attack on the organisation and its leadership in language and tone that is contrary to the culture and tradition of the organisation; and/or

Your conduct was dismissive and/or defiant of the processes and authority of the African National Congress’s decisionmaking mechanisms; and/or

Your statements included a direct attack on and undermining of a long-held principle of the ANC, namely democratic centralism; and/or

The cumulative effect of the above was to bring the ANC into disrepute and undermine the unity and cohesion of the organisation as contemplated in the above-stated rules.

COUNT TWO:

On or about 21 July 2017, you posted on Facebook a statement, copy of which is appended hereto marked Annexure E.

The said statement was: by its nature a public

● statement and not within the structures of the organisation; alternatively, you knew or ought to have known that the statement would become public; and/or

disrespectful to the KZN

● provincial executive committee of the ANC; and/or

dismissive and defiant of the

● political authority of a recognised structure of the organisation; and/or

Insulting and indeed defamatory of the provincial leadership of the ANC in Kwazulu-natal; and/or

The said statement is in breach of the ANC constitution as set out above.