Save to state that the substance of the applicant’s challenges is denied as appears
more fully hereunder, no issues arise.
3. Ad Para 3.9
No issues save to point out that much of the evidence that the applicant wishes to
place reliance upon is not part of the papers received by the 23rd respondent either
on the 10th or the 11th of August 2018. For instance, the separate bundle is absent,
the photographs are absent and the videos he refers to are absent. It is not clear
whether the applicant filed the separate bundle, videos and photographs with the
Registrar of the Constitutional Court on the 10th of August 2018.
4. Ad Para 4.1
Save to deny the veracity of the applicant’s statistical/ mathematical grounds for
challenging the presidential election return, no issues arise. A statistical report,
referenced hereunder, is attached to my affidavit refuting the applicant’s
contentions.
5. Ad Para 4.2-4.4
This is denied. I deal in detail with the substance of the applicant’s allegations
against the Electoral Commission below. Suffice to state that there is no basis for the
conclusions made by the applicant that there were constitutional and electoral law
violations perpetrated by the 23rd respondent in its administration of the 2018
general elections. Further, the separately bound volume that the applicant refers to
as the “123 series” was not served on me or the 23rd and 25th respondents. The