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

Rules for the Conduct of Proceedings in the Labour Appeal Court

9. Heads of argument

 

 

1) The appellant must deliver a copy of the heads of argument not later than 15 days before the hearing or not later than any earlier date determined by the Judge President. The original plus three copies of the heads of argument must be filed with the registrar.

 

2) The respondent must deliver a copy of the heads of argument not later than 10 days before the hearing or not later than any earlier date that may be determined by the Judge President. The original plus three copies must be filed with the registrar.

 

3) The heads of argument of the appellant and the respondent 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 textbook 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) 130D; Jones v Clark (Pty) Ltd a.o. (1990) 15 ILJ 1010 (LAC) 1031D).