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Labour Relations Act, 1995 (Act No. 66 of 1995)

Rules for the Conduct of Proceedings in the Labour Court

18. Heads of argument



1) The court may at any time call on the parties to deliver concise heads of argument on the main points that they intend to argue.


2) The heads of argument must -
a) include a chronology of the material facts;
b) in its first reference to a factual allegation contain a page and paragraph or line reference to the record or bundle of documents;
c) include a list of the authorities referred to in the heads of argument;
d) in its first reference to a text book specify the author, title, edition and page number (in that order for example: Smith, Labour Law, 2nd ed., 44); and
e) in its first reference to a reported case must contain the full name of the case, the year, volume, commencement page, division of the court, and page and margin reference to which specific reference is made (for example: National Union of Hotel Workers a.o. v Smith (Pty) Ltd 1990 1 SA 127 (A) 130(D); Jones v Clark (Pty) Ltd a.o. (1990) 15 ILJ 1010 (LAC) 1031D).