Falcon Gold Zimbabwe v Pfura Rural District Council

### Preamble
Judgment No. SC 79/21
1
Civil Appeal No. SC 131/19
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REPORTABLE:     (76)

FALCON     GOLD     ZIMBABWE

v

PFURA     RURAL     DISTRICT     COUNCIL

SUPREME COURT OF ZIMBABWE

GARWE JA, MAVANGIRA JA & MATHONSI JA

HARARE: 8 OCTOBER 2019 & 24 JUNE 2021

T. Zhuwarara, for the appellant

T. Mpofu, for the respondent

GARWE JA

[1]	This is an appeal against the whole judgment of the High Court of Zimbabwe sitting at Harare granting the respondent’s claim against the appellant in the total sum of US$120 000 together with interest thereon and costs of suit.  The amount represents land development levies for the period 2009 to 2013 which the respondent claimed were outstanding in terms of the Rural District Council Act, [Chapter 29:13] (“the Act”). In determining that the appellant was liable to pay the sum claimed by the respondent, the court a quo interpreted the word “owner” as defined in s 95 of the Act as including an “owner of rural land” provided for in s 96(1)(a) of the same Act.  It consequently determined that the appellant, being the holder of mining claims registered with the Secretary of Mines, was liable, qua owner of rural land, to pay the levies in question.

[2]	Having given due consideration to the provisions of both ss 95 and 96 of the Act, I hold that the respondent could only have properly claimed a levy from the appellant in terms of s 96(1)(b), subject to the qualification in that subsection being satisfied.  Initially, the respondent’s claim against the appellant was in terms of this subsection. It however proceeded to amend its claim and demanded payment of the levies in terms of subs (1)(a) of s 96 of the Act.  That subsection, in my considered view, does not empower the respondent, as a Rural District Council, to impose a levy on an entity, such as the appellant.  My reasons for so holding follow hereunder.

FACTUAL BACKGROUND

[3]	The respondent is a Rural District Council constituted in terms of the Act, whilst the appellant is a duly registered company carrying on mining activities within Zimbabwe.  Since 1987 the appellant has held a number of iron and magnetite mining claims in two areas falling under the jurisdiction of the respondent known as Gungwa and Chiutsa.  The respondent imposed land development levies on the appellant initially in terms of s 91(1)(b) of the Act which provides that a local authority may impose the same in respect of owners of mining locations situate on land within the council area. It subsequently altered the basis of its claim and instead demanded payment in terms of s 96(1)(a) of the Act. The appellant settled part of the land development levies claimed but did not do so in respect of the Gungwa mining claims.  A dispute arose between the parties as to the liability of the appellant to pay the levies claimed.

PROCEEDINGS BEFORE THE HIGH COURT

[4]	In August 2013, the respondent instituted an action in the High Court claiming the levies it considered were outstanding.  The appellant defended the claim, arguing that it was not liable to payment of the levies.  The usual pleadings followed and, at a pre-trial conference, the court referred the matter to trial as a special case.

[5]	In due course the parties filed a statement of agreed facts.  That statement of agreed facts is reproduced hereunder:

“1.     Plaintiff is Pfura Rural District Council, a local authority of Mount Darwin, constituted in terms of the Rural District Council Act, Chapter 29:13.

2.        	Defendant is Falcon Gold Zimbabwe Limited, a company incorporated according to the laws of Zimbabwe which carries out mining activities in Zimbabwe.

3.   	At all material times, the defendant was the holder of 320 magnetite mining claims in Gungwa and 151 Iron and Magnetite mining claims in Chiutsa, both areas falling under the plaintiff Rural District Council.  The said mining claims have since been disposed of and are no longer held by the defendant.  The mining claims were held in terms of certificates of registered title which form pp 5-6 to the plaintiff’s bundle of discovered documents.

4.   	Iron and Magnetite are base minerals as defined in the Mines and Minerals Act Chapter 21:05.

5.   	During the period of its ownership of the claims, the defendant did not work on the claims and had in fact never conducted any mining activity on them nor did defendant employ any labour on the claims.  The defendant merely held the claims and left them lying idle for possible future mining operations which did not take place.

6.  	The plaintiff is entitled to and may impose a land development levy upon all persons who are owners of mining locations situated on rural land within the plaintiff’s council area in accordance with the provisions of s 96(1)(b)(i) and (ii) of the Rural District Councils Act Chapter 29:13, hereinafter referred to as “the Act”.

7.  	 The scales of such land development levies are set out in the Third Schedule of the Act.

8.  	 The plaintiff is also entitled to and may impose a land development levy upon all persons who are owners of rural land within council area in terms of s 96(1)(a) of the Rural District Councils Act Chapter 29:13.

9.  	Plaintiff imposed a development levy on defendant company in terms of s 96(1)(a) of the Rural District Councils Act Chapter 29:13, see invoices from plaintiff showing outstanding amounts due from defendant, being p 7 to the plaintiff’s bundle of discovered documents.

10. 	Land development levies are incorporated into the Council’s annual budget and are subject to approval by the Minister of Local Government, Urban and Rural Development in accordance with the provisions of the Public Finance Management Act Chapter 22:19.

11. 	In the year 2009, 2010, 2011, 2012 and 2013 respectively, the plaintiff gave notice by way of publication in the local press, of its intention to impose or increase levies or other licences in areas falling under its jurisdiction.  Copies of such publication have been filed of record as pp 18 to 22 of the plaintiff’s bundle of discovered documents.

12.  	Thereafter, the plaintiff then presented a budget to the Minister for the respective years in which the levies for a claim holder’s permit in respect of mining claims was set at $100 per claim in respect of each year.

13. 	The respective yearly budgets, copies of which are filed of record, were approved by the minister in accordance with the provisions of the Public Finance Management Act.

14.  	No invoices were issued to the defendant in the year 2009 and 2010.  However, in the year 2011, defendant requested permission to transfer its Chiutsa mining claims which are situated in plaintiff council’s area to another company but the plaintiff refused to grant defendant permission to transfer such claims demanding that defendant pay the land development levies first before transfer could be effected.  Defendant requested that the levies be reduced to $38 per claim but plaintiff imposed a levy of $75 per claim.  In consequence, defendant paid plaintiff the levies only in respect of the Chiutsa claims at an agreed reduced rate of $75 per claim only to enable the transfer of the mining claims to be processed but did not pay for the Gungwa claims. Invoices for the Gungwa claim were issued in 2012 (see para 7).

15. 	Plaintiff alleges that the levy was raised in accordance with the provisions of s 96(1)(a) of the Act which provides that council may impose levies upon owners of rural land situated within council area.

16.  	Plaintiff was requested to provide documentary proof that defendant was an owner of rural land situated within the plaintiff’s council area by virtue of a request for further and better particulars filed on behalf of the defendant on 16 June 2014.

17.  	In response to such request, the plaintiff filed their response on 19 June 2014 to which they annexed four certificates of Registration Numbers 21615, 21616, 21617, 21618 all dated 5 December 1990 issued to defendant by the Mining Commissioner Harare in respect of the Gungwa claims as proof of defendant’s ownership of rural land situated within the plaintiff’s council area.  Plaintiff did not produce any title deeds or give any description, location or extent of the land allegedly held by the defendant.

18.  	Plaintiff maintains that defendant is liable to pay US$75 per claim per year plus interest at the prescribed rate up to the year 2012 for each of the 320 Gungwa mining claims held by defendant.

19. 	Defendant avers that such levies are unlawful and denies that they are liable to pay the plaintiff any levies at all by virtue of the fact that:

a) 	they are not owners of any rural land situated in the plaintiff’s council area and have never at any stage been owners of any land situated in the said area.

b) 	at all material times, did not conduct any mining activity on the Gungwa claims or any of their other claims situated in the plaintiff council area and have in fact never done so and have therefore never produced any mineral or declared any output in tonnes in accordance with the provisions of the Mines and Minerals Act.

c) 	defendant avers that plaintiff has no valid legal basis to make any claim against defendant for any land development levies.

20. 	 At a pretrial conference held before the Honourable Mr. Justice Zhou on 30 April 2015, the judge ordered that the matter be referred to trial as a stated case on the issues raised on the joint pretrial conference memorandum filed of record.

21.  	Consequently, this Honourable court is being called upon to determine the legality or otherwise of the levies sought to be imposed upon the defendant by the plaintiff as more fully set out here under.

22.  	The parties will articulate their respective cases in the heads of argument to be filed in accordance with the order of the judge at the pretrial conference.”

[6]	The issues of law that arose from the above facts were captured as follows:-

“(1) 	Whether or not plaintiff is entitled to raise a land development levy against defendant in accordance with the provisions of s 96(1)(a) of the Rural District Council’s Act Chapter 29:13 in respect of defendant’s Gungwa mining claims.

(2) 	If so, whether or not plaintiff is entitled to claim the sum of US$75 per claim per year for the years 2009 to 2013, when the Minister only approved US$100 per claim per year.

(3)	If so, whether or not defendant is liable to pay plaintiff development levy for the years 2009 to 2013 for the Gungwa mining claims in the total sum of US$120 000 being the total amount of the claim plus interest.”

[7]	At the hearing of the special case the respondent, as plaintiff, argued that the appellant, as owner of rural land in respect of the Gungwa mining claims, was liable to pay the outstanding levies.  Per contra, the appellant argued that, not being the owner of rural land under the jurisdiction of the appellant, it was not liable to the payment of the levies.  It further argued that it had never worked on the mining claims and consequently had not produced any output as defined in the Mines and Minerals Act [Chapter 21:05].  It therefore denied being indebted to the respondent.

[8]	After hearing argument from the parties and considering documents annexed to the statement of agreed facts, the court was of the view that the only issue that fell for determination was the interpretation to be given to the words “owner of rural land” in para (a) of subs 1 of s 96 of the Act.  The court was of the view that since the definition of owner includes a person in whose name a mining location is registered with the Secretary for Mines, the appellant was such an owner.  The court further found that, having paid the levies due in respect of Chiutsa mining claims, the appellant was estopped from now challenging the levy agreed upon of US$75 per claim instead of the US$100 per claim that had been approved by the Minister.  The court accepted that the council could reduce the amount of the levy as the Act allowed it to agree to the payment of an amount less than that prescribed by the Minister.  In the result, the court a quo granted the respondent’s claim for payment of the sum of US$120 000 together with interest and costs of suit.

PROCEEDINGS BEFORE THIS COURT

[9]	Unhappy with the determination of the court a quo, the appellant noted an appeal to this Court.  It raised two grounds of appeal in which it avers that the court a quo erred and grossly misdirected itself in two respects, namely:-

- in failing to appreciate and/or disregarding the distinction between mining locations and mining claims as provided for in the Mines and Minerals Act [Chapter 21:05].

- in finding that the appellant is an owner of rural land as defined in s 95 of the Act, notwithstanding that the appellant is not the holder of any mining locations within the jurisdiction of the respondent as provided for in s 95(d) of the Act.

[10]	At the hearing of the matter before this court, both parties made submissions on what they considered was the correct interpretation to be given to the words “owners of rural land” who are liable to pay levies in terms of s 96(1)(a) of the Act. Counsel for the appellant, whilst accepting that the appellant is an “owner” as defined in s 95 of the Act, has argued that s 96(1)(a) cannot be read in isolation but must be read together with s 96(1)(b) of the same Act which stipulates that such owners must produce and declare an output for them to be liable to the payment of development levies. Since it was common cause between the parties that the appellant had never produced any output (as defined in the Mines and Minerals Act) the appellant was not liable to pay the levies claimed.  The claims held by the appellant were never operationalised and consequently the appellant had no obligation to pay levies in view of the fact that non-productive mines for base minerals are not liable to pay such levies.  The appellant has therefore urged this court to allow the appeal with costs and set aside the decision of the court a quo.

[11]	In its heads of argument and oral submissions, relying on ss 95 and 96(1)(a) of the Act, the respondent has contended that the only requirement that makes owners liable to pay development levies is that they must own mining locations in land under a rural district council.  It has further submitted that there is significance in the fact that the provision refers to owners of rural land as opposed to owners of registered rural land. By virtue of the certificates of registered title in the appellant’s name, it is an owner on whom the respondent can impose levies in terms of s 96(1)(a), either as an owner of land falling within the council area or as an entity carrying on a specified business on land that falls within the council area.

ISSUE FOR DETERMINATION

[12]	There is but only one issue for determination before this court.  That issue is whether the appellant, which owned mining claims in the area under the jurisdiction of the respondent, is liable to pay a land development levy in terms of s 96(1)(a) as an owner of rural land despite the fact that s 96(1)(b) says only those owners of mining locations who are active and declare an output are liable to the payment of such a levy.  The issue therefore turns on the interpretation of the provisions not just of s 96(1)(a) but s 96(1)(b) as well.

[13]	I notice in passing that, in coming to the conclusion it did, the court a quo confined itself to the meaning to be given to ss 95 and 96(1)(a) of the Act.  It said nothing about s 96(1)(b) which qualifies the liability of owners of mining locations registered with the Secretary for Mines.

[14]	Section 95 of the Act defines an owner as (a) the person in whose name private land is registered in a Deeds Registry; or (b) a person who is party to an agreement which, on the fulfilment by him of the conditions prescribed by such agreement, entitles him to obtain transfer of private land; or (c) a person who lawfully holds under an agreement of lease land which is (i) the property of the trustees of the Rhodes Estate; or (ii) State Land; or (iii) Communal land set aside in terms of the Communal land Act, Chapter 20:04; or (d) a person in whose name a mining location such as is referred to in para (b) of subs (1) of s 96 is registered with the Secretary for Mines; provided that if such person has let or assigned his rights in such mining location to any other person, such other person shall be deemed to be the owner.

[15]	For the purposes of the Act, therefore, owner means a number of different things.  In order to determine whether the appellant is liable to payment of levies as owner of a mining location, one must pay due regard, not only to subs 1(a) but also subs 1(b) of s 96 of the Act.

[16]	Section 96 of the Act provides:

“96 Levies in Rural areas

Subject to this part, a council may impose a land development levy upon all person who, on the fixed date, are or who, at any time during the period of twelve months next following the fixed date become –

owners of rural land within the council area

Provided that-

If a person is liable to a land development by virtue of being an owner referred to in paragraph (b) of the definition of “owner” in section ninety-five, the council may impose the land development levy either on the person referred to in para (a) of that definition or on the person referred to in para (b) thereof but not on both;

If a registered owner of rural land holds any State land, which is within the council area and contiguous with his own land, in accordance with any enactment or agreement whereby such owner is entitled, upon the fulfilment by him of the conditions laid down in such enactment or agreement, as the case maybe, to obtain title to such State land, such State land shall be deemed to form part of the land of such owner for the purposes of the land development levy;

or

owners of mining locations on rural land within the council area mining for-

gold, silver, platinum or precious stones and employing more than five workers; or

base minerals as defined in the Mines and Minerals Act [Chapter 21:05] and declaring an output in tonnes in accordance with the provisions of that Act;

Licensed dealers who carry on the business in respect of which their licences are issued on rural land within the council area; or

– (e) …… (not relevant).”

[17]	The Mines and Minerals Act, in its definition section, defines “mining location” as “a defined area of ground in respect of which mining rights, or rights in connection with mining, have been acquired under the Act or which were acquired under any previous law relating to mines and minerals and which were held immediately before 1 November 1961”.

THE LAW ON INTERPRETATION OF STATUTES

[18]	It is the interpretation of ss 95 and 96(1)(a) and (1)(b) of the Act which lies at the centre of the dispute in this matter.  The law on the interpretation of statutes and other legal documents is now well established in this jurisdiction.  It is the duty of the court to give effect to every word which is used in a statute unless necessity or absolute intractability of the language employed compels the court to treat the words as not written – Keyter v Minister of Agriculture 1908 NLR 522.  This is the golden rule of interpretation which, put otherwise, stipulates that the language in the document is to be given its grammatical and ordinary meaning, unless this would result in some absurdity, or some repugnance or inconsistency with the rest of the instrument – Coopers and Lybrand & Others v Bryant 1995 (3) SA 761, 767 (A). In Chegutu Municipality v Manyora 1996 (1) ZLR – 262 (SC) this Court remarked that there is no magic about interpretation and that words must be taken in their context.

[19] More recently the Constitutional Court of Zimbabwe in Chihava v The Provincial Magistrate Francis Mapfumo CCZ 6/15 stated at pp 7-8 of the unreported judgment:

“The principles set out in the dicta cited above can aptly and instructively be summarized as follows:

the Legislature is presumed not to intend an absurdity, ambiguity or repugnancy to arise out of the grammatical and ordinary meaning of the words that it uses in an enactment.

Therefore, in order to ascertain the true purpose and intent of the Legislature, regard is to be had, not only to the literal meaning of the words, but also to their practical effect.

In this respect,

a) the words in question must be capable of an interpretation that is ‘consistent’ with the rest of the instrument in which the words appear; …”

[20]	 In Zimbabwe Homeless People’s Federation & Ors v Minister of Local Government and National Housing & 3 Ors SC 94/20, this court also stated:

“It is axiomatic that the Constitution must be interpreted in an holistic and seamless fashion.  Each provision is to be interpreted, without doing violence to the actual language used, in a manner that is consistent and accords with every other relevant provision, so as to achieve the underlying purpose of those provisions. They must be construed as being mutually complementary rather than being contradictory to one another.  In short, the Constitution must be construed as a unified whole.”

[21]	Whilst the above remarks were made in the context of the interpretation of provisions of the Constitution, there is no doubt that the remarks apply with equal force to the interpretation of statutory provisions generally.  In this regard, E A Kellaway, Principles of Legal Interpretation, Statutes, Contracts & Wills, states as follows at p 163:-

“Where two sections of an enactment appear to clash, a similar principle can be applied.  The two sections should, if possible, be so construed as to be consistent with each other.  Consequently if there are two sections in an Act which seem to clash but which can be interpreted so as to give full force and effect to each, then such an interpretation is to be adopted rather than one which will partly destroy the effect of one of them, as in all cases a construction which would promote the more effective attainment of the clear object of an enactment should be preferred to an interpretation which would hamper its realisation.  In any event, if possible, different parts of the same statute should be construed so as to avoid conflict between them.  Indeed, in Re Marr Nicholls LJ said that if there is a conflict between two sections in the same Act you have to try to reconcile them as best as you may.  If you cannot, you have to determine which is the leading provision and which is the subordinate provision, and which must give way to the other.”

The above remarks in my view correctly reflect the law in this regard.

WHETHER THE APPELLANT WAS OWNER OF RURAL LAND

[22]	As already noted earlier in this judgment, s 95 of the Act defines “owner” to mean a number of things. It means the person in whose name private land is registered in the Deeds Registry.  It also means a person who is party to an agreement which, on its fulfilment, entitles him to obtain transfer of private land.  It also means a person who lawfully holds, under an agreement of lease, land which is the property of the Rhodes Estate, State land or Communal land.  It finally means a person in whose name a mining location such as is referred to in s 96(1)(b) of the Act is registered with the Secretary of Mines, subject to the proviso that if such person has let or assigned his rights in such mining location to any person, such other person shall be deemed to be the owner.

[23]	The above reference to a person in whose name a mining location is registered is not unqualified in the Act.  The mining location must be such as is referred to in subs 1(b) of s 96 and registered with the Secretary of Mines. To put the matter beyond doubt, para (b) of subs (1) of s 96 says a development levy may be imposed, inter alia, on owners of mining locations on rural land within the council area.  It is clear that both ss 95 and 96(1)(b) apply to owners of mining locations situated on rural land within the Council area.  The two provisions do not relate to the ownership of rural land within the Council area to which s 96(1)(a) of the Act applies.

[24]	 It is para (a) of subs (1) of s 96 of the Act that provides for the imposition of a development levy upon owners of rural land.  “Rural land”, in terms of s 95 of the Act, means any land other than urban land.  Paragraph (a) of subs (1) of that section does not provide for the payment of a levy by anyone who is not the owner of rural land.  Section 96 itself makes a clear distinction between owners of rural land and owners of mining locations.  If the term “owner of rural land” were to include an “owner of a mining location situate on rural land within the council area”, then subpara (b) would have been unnecessary and otiose.

[25]	Section 96 of the Act evinces a clear intention to make provision for the payment of development levies by different classes of people.  These include (a) owners of rural land (b) owners of mining locations registered with the Secretary for Mines situate within the Council area (c) licensed dealers carrying on business whose licenses are issued by Council (d) owners of land deemed to be rural land by virtue of a resolution of council in terms of s 102 of the Act (e) persons carrying on a specified business on rural land within the council area and (f) holders of permits issued in terms of s 9 of the Communal Land Act [Chapter 20:04].

[26]	Consequently, as correctly submitted by Mr. Zhuwarara for the appellant, the definition of “owner” in s 95 cannot be read without reference to subpara (b) of subs (1) of s 96.  Section 95 itself says so. Put otherwise, the owner of a mining location cannot be both “owner of rural land” and “owner of a mining location” for purposes of s 96 of the Act.  Such an interpretation would result in an absurdity so glaring that this could not possibly have been the intention of the legislature. As correctly submitted by the appellant in its heads of argument filed in the court a quo, there is a distinction between ownership of land and ownership of mining locations.  Ownership of mineral rights is separable from ownership of the land surface on which mining rights are located. The provisions of ss 95 and 96 clearly recognize the legal distinction between land ownership and ownership of mining rights. The payment of a land development levy in these two situations is separately provided for in s 96 of the Act.

[27]	Section 96(1)(a) is clear and unambiguous.  It imposes the payment of a levy on an owner of rural land. Per contra s 96(1)(b) imposes the obligation on an owner of a mining location registered with the Secretary for Mines.  Subparagraph (a) of subs (1) of s 96 is clearly inapplicable on the facts of this case.

[28] 	In the present matter, it was common cause that the appellant did in fact hold mining claims on land falling under the jurisdiction of the council.  It was also common cause - in the statement of agreed facts - that the appellant had never worked or operated on these claims.  The appellant had held onto the claims and had eventually sold its rights in them without having operationalised them.

[29]	Subparagraph (b) of subs (1) of s 96 is qualified.  The owner of such mining location on rural land within the council area must mine for gold, silver, platinum or precious stones and be employing more than five workers.  Alternatively, the owner must be mining for base minerals as defined in Mines and Minerals Act and declaring an output in tonnes in accordance with the provisions of that Act.  An “output” in terms of the Mines and Minerals Act means (a) in respect of precious stones, precious stones which have been recovered from any mining location (b) in respect of any other mineral, ore which has been mined and reduced to a saleable form or which is in a saleable form on being mined.

[30]	It is clear, from a reading of s 96(1)(b) of the Act, that owners of mining locations situated on rural land within the council area are liable to payment of a development levy if they mine for gold, silver, platinum or precious stones and employ more than five people. They are also liable if they mine for base minerals as defined in the Mines and Minerals Act and declare an output in terms of that Act. The ordinary grammatical meaning of that subparagraph is that a non-productive mining location cannot attract liability for payment of a development levy.

[31]	It was agreed between the parties that the appellant never undertook mining operations on the mining claims and that it never declared an output.  Therefore s 96(1)(b) of the Act was not applicable to the appellant and no development levy was, as a consequence, payable by it to the Council.  The appellant was never brought within the letter of the law for it to be liable to payment of the development levy. In this regard, the remarks by Lord Cairns in Pakington v Attorney General, 1869 LR 4 H.L. 100, 122 cited with approval by Lord Russell in Inland Revenue Commissioners v Duke of Westminister, 1936 (A.C. 1), 19-20 are apposite.  The learned judge remarked:

“As I understand the principle of all fiscal legislation it is this. If the person sought to be taxed comes within the letter of the law he must be taxed, however great the hardship may appear to the judicial mind to be.  On the other hand if the Crown, seeking to recover the tax, cannot bring the subject within the letter of the law, the subject is free, however apparently within the spirit of the law the case might otherwise appear to be.”

The above remarks are apt given the circumstances of this case.  That this was a tax is without doubt – Nyambirai v National Social Security & Anor 1995(2) ZLR 1 (SC).

DISPOSITION

[32]	The court a quo was incorrect in coming to the conclusion that the appellant was an owner of rural land as provided for in subpara (a) of subs (1) of s 96 of the Act.  As a matter of fact, the appellant was an owner of a mining location on rural land falling under the council.  Therefore it is subpara (b) of subs (1) of that section that was applicable.  The appellant, who held mining locations for base minerals, never operationalised the mining rights and, importantly, never declared an output.  The appellant was consequently not liable to pay a land development levy. For this reason, the appeal must succeed.

[33]	On the issue of costs, these should follow the event.

[34]	It is accordingly ordered as follows:

1. The appeal be and is hereby allowed with costs.

2. The judgment of the court a quo is set aside and substituted with the following:

“The plaintiff’s claim be and is hereby dismissed with costs.”

MAVANGIRA JA	:		I agree

MATHONSI JA	:		I agree

Gill, Godlonton & Gerrans, appellant’s legal practitioners

C. Mpame & Associates, respondent’s legal practitioners