Court Filings

Please find below the key court filings in the case to date. Please check back regularly as this page is updated on an ongoing basis.

Founding Affidavit
Founding affidavit – annexures
Applicant Affidavits
Expert Affidavits
Additional Court Filings
Applicant’s Replying Affidavit and Evidence
Anglo Strike Out Application
Applicants’ Heads Of Argument: Certification Of Class Action
Respondent's Heads of Argument in the Certification Application
HRW Amicus Heads of Argument
HRW Notice of Motion and Founding Affidavit
Human Rights Watch Notice of Motion
UN Special Rapporteurs Notice of Motion
UN SR Amicus Founding Affidavit
UN SR Amicus Heads of Argument
Written Submissions of First and Second Amicus Curiae
Judgement of the application for admission of UN Groups and Human Rights Watch as amicus curaie.
Written submissions of the third to Seventh amici Curiae (UN rapporteurs)
Respondent’s Heads in Response to the Amici Curiae

“…childhood Pb poisoning in Zambia’s Kabwe mining town is among the highest in the world, especially in children under the age of 3 years.”


John Yabe 2015