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This document consists of the applicants' (defendants') heads of argument filed in the High Court of South Africa (Western Cape Division) on 15 May 2019. The applicants, including environmental lawyers and a community activist, are seeking an order to compel Mineral Sands Resources (Pty) Ltd (MSR) to disclose documents relevant to a defamation lawsuit. MSR is suing the applicants overS for statements made during a University of Cape Town course on 25 January 2017, which alleged that MSR operated its Tormin Mine in breach of mining, environmental, and land use planning laws. The applicants argue that the requested documents are essential to prove the truth of their statements and to protect their constitutional rights to freedom of speech and academic freedom.

Mineral Sands Resources (Pty) Ltd has applied for consent under section 102 of the Mineral and Petroleum Resources Development Act (MPRDA) to expand the mining area of the Tormin Mine in the Western Cape. The request includes adding the 'Northern 10 Beaches', an inland 'Strand' line area, and infrastructure for a Mineral Separation Plant.