of 10 985 polling stations and out of ten provinces is by no means representative of the pattern that the applicant alleges in his paragraph 4.6. No trend can be established by the applicant’s sample. 27.2. In any event, where the actual data for the 2018 general election is available, no meaningful purpose can be served by the hypothetical that is postulated by the applicant’s sample. But even if one considers sampling that was being done during the conduct of the 2018 general election by the largest election observer group on the ground, ZESN, their report shows consistency with the results declared for the presidential election by the Electoral Commission. I attach a copy of that report hereto marked Annexure ‘S’. 27.3. Applicant also alludes to having sourced the said V11s from social media, suffice to remind him that a V11 form is obtained through the provisions of s64(1)(d1) of the Electoral Act. The authenticity of his source of data is thus in doubt. 28. Ad Para 4.7 This is denied. 28.1. Once again, the applicant makes a bald averment based on no evidence. Nothing is placed before the court to prove or demonstrate the alleged stopping of counting which he seeks to present to the court as a fact. No affidavits by election agents stating that counting was stopped and at what polling stations it

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