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This document contains the heads of argument submitted by the MEC and the Chief Director of the North West Provincial Government (the 1st and 2nd Respondents) in an appeal before the Supreme Court of Appeal of South Africa. The appeal challenges an ex post facto environmental authorization granted under section 24G of the National Environmental Management Act (NEMA) for the Kgaswane Country Lodge, located in the Magaliesberg Protected Environment. The respondents argue that the appellant's request for the demolition of the lodge is disproportionate and that the review application became academic after the appellant failed to obtain an urgent interdict to stop construction.

A formal request from the Centre for Environmental Rights and a coalition of twelve other NGOs to the South African Minister of Mineral Resources. The document urges the Minister to use her discretion under Section 49 of the Minerals and Petroleum Resources Development Act (MPRDA) to prohibit or restrict prospecting and mining in areas of critical biodiversity and hydrological value to protect the environment and mitigate climate change impacts.