40.2. Verification was done in terms of the law. The V11 and V23 forms were available and were used in that process. 40.3. The excel spreadsheet was a tool for addition of totals. It is not part of the verification in terms of the law. Even when one considers the statutory framework set out in s110 of the Electoral Act, verification is provided for under s110(3)(d) and thereafter addition of the verified totals is provided for under s110(3)(e). The later does not factor into the former. The verification provided for in s110(3)(d) was done. 40.4. The applicant had election agents at polling stations across the country. Whilst he was granted unlimited access to V11s and V23s at the national command centre during the verification process, he himself also had the same source documents available to him through his own election agents. On what grounds the Electoral Commission would then seek to deny his chief election agents access to source documents that it had already given to his election agents across the country is not explained and demonstrates that the version of events narrated by the applicant is not true. His chief election agents had access to all the source documents for the verification exercise. They did access those documents. They made notes from those documents. They raised no queries on those documents. 41. Ad Para 6.2.5 This is denied.

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