Krawitz/Cape Union Mart and PSC et al — Consolidated Summary of Court Papers
Preface
This document consolidates, section by section and largely in the parties’ own words, the affidavits and heads of argument filed to date in Cape Union Mart International (Pty) Ltd and Philip Krawitz v Maghmuda Ockards and Others (Case №2025–092980), a Western Cape High Court application by the retailer and its principal shareholder for an interdict against consumer-boycott protests organised by the Palestine Solidarity Campaign Western Cape.
My own analysis of the Applicants’ Founding Affidavit appears in my article Charge of Antisemitism 1: Cape Union Mart and Phillip Krawitz versus Palestine Solidarity Campaign Western Cape (Medium, July 2025). That piece offers a scholarly, not a legal, assessment of the Applicants’ case, reading the Founding Affidavit through the lens of political theory, semiotics and critical genocide studies rather than the law of defamation or hate speech. It argues that Krawitz’s stated separation of the Israeli state from the Israeli government is untenable given his leadership roles in Keren Hayesod, the Jewish Agency for Israel, United Herzlia Schools and the United Jewish Campaign — bodies the article characterises as organs of Zionist state-building rather than neutral philanthropy — and concludes on that basis that Krawitz, and through him Cape Union Mart, are best understood as complicit, in the scholar Michael Rothberg’s sense of that term, in Israel’s conduct in Gaza, rather than as innocent targets of defamation. On the antisemitism allegations specifically, the article argued that the protest material’s references to swastikas, Nazism and genocide target Israeli state conduct rather than Jewish identity as such, and are therefore not inherently antisemitic — while flagging, with reference to the Constitutional Court’s judgment in the Masuku case, a real doctrinal risk that a South African court could nonetheless read such references as coded attacks on Jews as Jews.
This document consolidates, section by section and largely in the parties’ own words, the affidavits and heads of argument filed to date in Cape Union Mart International (Pty) Ltd and Philip Krawitz v Maghmuda Ockards and Others (Case №2025–092980), a Western Cape High Court application by the retailer and its principal shareholder for an interdict against consumer-boycott protests organised by the Palestine Solidarity Campaign Western Cape.
1. Founding Affidavit (Philip Krawitz, deposed June 2025)
The Essence
Krawitz frames the application as a response to a “relentless boycott campaign” against Cape Union Mart that, he says, has crossed from legitimate protest into unlawful conduct (Founding Affidavit [FA] paragraphs [§§] 5–6): false claims that he and the company fund genocide and “kill babies” (FA §6.1), public circulation of his and his wife’s images (FA §6.2), exposure of customers to Nazi symbolism (FA §6.3), and reputational and economic harm (FA §6.4) — pursued, he says, despite repeated attempts to resolve matters amicably (FA §7).
Background
Krawitz sets out his family history (his grandfather founded the business in 1933 after fleeing persecution) (FA §§12, 28), the company’s scale (approximately 3,000 employees and 270 stores) (FA §29) and its donation policy, which he says is restricted to South African causes (FA §§31–32). He details his personal leadership roles — including chairperson of Keren Hayesod South Africa and trustee of the Cape Town Holocaust & Genocide Centre (FA §§33.1, 33.4) — and traces the 2015 Keren Hayesod award back to 2014 fundraising for a humanitarian Victims of Terror Fund (FA §§34–42), arguing there is no rational link between that award and the war in Gaza that began in October 2023 (FA §58.3).
The Protests
A chronological, heavily annexure-referenced account running from November 2023 to mid-2025 (FA §§44–110). It records the PSC pamphlet naming Gamiet, Jeenah and Sylvester as contacts (FA §§45–47); chants accusing Krawitz of genocide and child-killing (FA §§49, 69); a succession of posters (a devil’s-horns manipulation of his photograph (FA §89), a “Synagogue of Satan” placard (FA §§79–80), swastika/Star-of-David pairings (FA §§63, 68, 81), and a fabricated quotation attributed to him (FA §§89.4, 90–96)); a store-entrance blockade (FA §99); and the identification of each respondent through photographs and social media activity (FA §§100–110). Krawitz also gives his own account of a widely shared, and in his view misquoted, interview clip (FA §§92–96).
Unlawful Conduct, Clear Right, Irreparable Harm
Krawitz argues the statements are defamatory per se and impair his dignity as a Jew, particularly through the swastika displays (FA §§111–114, 131–132). He states that Hawks officers warned of a credible threat to his life, prompting him to employ bodyguards and use an armoured vehicle (FA §§115–118). He asserts common-law rights to reputation and dignity together with statutory rights under the Regulation of Gatherings Act (FA §§119–129), and argues the harm is ongoing and cannot be adequately addressed through damages alone, citing the difficulty of identifying anonymous protesters and quantifying commercial loss (FA §§134–137, 145.2–145.4).
No Alternative Remedy / Costs
He explains the delay in litigating — an initial hope for an amicable resolution, and security concerns about drawing further attention to the dispute (FA §§147–153) — and seeks costs only against respondents who oppose the application (FA §§156–157).
2. Second to Fourth and Seventh Respondents’ Answering Affidavit (Usuf Chikte, for the PSC) (deposed November 2025)
Part A — Overview
The PSC frames its campaign as a lawful consumer boycott and political expression protected under sections 16 and 17 of the Constitution (Answering Affidavit [AA] paragraphs [§8]), targeting Krawitz’s institutional ties to Israel rather than his Judaism (AA §§11–12), and denies antisemitic motive, stating the PSC “stands firmly against all forms of racism, including antisemitism” (AA §13). It characterises the relief sought as an unconstitutional prior restraint that would “eviscerate” the PSC’s rights (AA §§16–17), and sets out the affidavit’s roadmap through Parts B to K (AA §19).
Part B — Relief sought and constitutional issues
Sets out the relief sought in the Notice of Motion — restraining alleged harassment and store obstruction (prayers 1.1–1.2), the genocide/killing-children statements (prayers 1.3–1.6), a blanket ban on “defamatory” statements (prayer 1.7), and compliance with the Gatherings Act (prayer 1.8) (AA §20). Chikte notes that Krawitz has publicly foreshadowed seeking an apology and a donation despite this not being part of the Notice of Motion, which the PSC says reveals a punitive and performative motive (AA §22), and grounds its opposition in the constitutional rights to freedom of expression and assembly (AA §§23–25).
Part C — Point in limine: unclean hands
The affidavit’s most pointed section (AA Part C). It argues the FA misleadingly omits that other groups — including the Cape Youth Collective (CAYCO), the BDS Movement, the Cape Town Intifada, Mothers for Gaza, and South African Jews for a Free Palestine — also protested Cape Union Mart, and that it was a CAYCO member, not the PSC, who used the loudhailer at the November 2023 protests (AA §§27–29). It quotes a December 2024 Krawitz interview in which he describes hesitating to sue a “young Jewish” protester and instead targeting the PSC — described as a “poor… Muslim family” — to avoid the optics of “Jew versus Jew” (AA §33), identifying that same protester as the person who led the “Philip, Philip, you can’t hide” chant the FA attributes to the PSC generally (AA §37). Chikte argues this shows selective, identity-based enforcement rather than even-handed protection of legal rights (AA §§34–36).
Part D — PSC identity and protest conduct
Describes the PSC as a secular, multi-faith civil-society body committed to non-violent protest (AA §§67–70), sets out its marshalling protocols — briefing members not to block store entrances or harass shoppers, and liaising with mall security and police (AA §§74–76) — and names which respondents were responsible for demonstrations at each shopping centre. It denies that any swastika imagery relied on by the applicants was PSC-produced, while maintaining that such imagery, where used by other protesters, condemns Israeli state conduct rather than expressing hatred of Jews (AA §§52, 95), and states that no PSC member has ever been arrested or charged (AA §80).
Part F — Krawitz’s institutional roles
The evidentiary core of the truth defence (AA Part F). It details claims that Keren Hayesod is “effectively a governmental entity” funding IDF-linked programmes, including support for roughly 3,600 foreign “lone soldiers” and pre-military mechinot academies (AA §§146–147), and that Krawitz also sits on the Board of Governors of the Jewish Agency for Israel (JAFI), which runs the Garin Tzabar programme recruiting diaspora Jews into the IDF (AA §§160–165). It further cites his chairmanship of the Cape Town United Jewish Campaign and Telfed’s promotion of the IDF’s Mahal volunteer programme (AA §§166–171), concluding that his fundraising “strengthens the Israeli military” even where funds are not literally spent on weapons (AA §173). These are the specific claims the Applicants’ Heads of Argument rebuts using confirmatory affidavits from Keren Hayesod’s and the Jewish Agency for Israel’s chief financial officers.
Part G — Impugned statements: not defamatory
Denies PSC authorship or responsibility for many of the posters relied on — including disclaiming a statement by BDS’s Roshan Dadoo (AA §179) and the swastika-Israeli-flag imagery in annexure “C15” (AA §52.1) — and argues that, where statements are attributable to the PSC, the “genocide funder” and “supports genocide” characterisations are either substantially true, given Krawitz’s roles set out in Part F, or protected fair comment on a matter of public interest (AA §§189–224). It characterises chants such as “how many kids have you killed today?” as rhetorical moral condemnation rather than a literal accusation (AA §228), and denies personal malice, saying the PSC’s criticism targets Krawitz’s conduct and public roles rather than his Jewish identity (AA §§204–206).
Part H — Lawfulness of protest conduct
Asserts that no PSC member was ever arrested for unlawful conduct during the campaign and that police were regularly present without incident (AA §§237, 240), that marshals actively policed compliance with the law, and denies harassment of customers or obstruction of store entrances (AA §§245–251). It disputes that any threat against Krawitz is linked to the PSC or supported by a police docket, and asks that the FA’s threat allegations be struck out as vexatious if relied on for relief (AA §§252–255). On the Gatherings Act, it says many demonstrations fell under the 15-person notification threshold and that a City of Cape Town official confirmed no notice was required below that number (AA §§256–260), and defends face coverings as Covid-19 masks or keffiyehs rather than deliberate concealment (AA §267).
Part I — Setlogelo test not met
Argues the applicants have not established a clear right — the impugned speech being truth, fair comment, or a matter for the Equality Court rather than this application (AA §271) — that injury is neither proven nor reasonably apprehended, pointing to the absence of police complaints or arrests and questioning why the application was not brought urgently if the threat was genuine (AA §§272–273), and that adequate alternative remedies exist, including a damages action and Equality Act proceedings (AA §274).
Part J — Grounds for refusing each prayer / Costs
Attacks prayer 1.7 (against publishing “any defamatory statements”) as impermissibly vague, opposes conferring enforcement powers on private security companies (AA §278), and seeks costs — including for three counsel on Scale C — should the application fail, characterising the litigation itself as an abuse of process aimed at silencing protected speech (AA §§277–283).
Part K
Answers the Founding Affidavit paragraph by paragraph on the foundation laid in Parts A–J (AA §§284–334), and closes by asking that the application be refused with costs (AA §335).
3. Individual Respondent Affidavits
First Respondent (Maghmuda Ockards)
Denies PSC membership, stating she is a member of the public who attends pro-Palestinian protests (Ockards Affidavit [OA] paragraph [§] 5), and adopts the PSC’s Part G defence for each poster she is shown holding, while factually disputing some of the FA’s dating and attribution. She admits wearing a skull mask intermittently at the 9 December 2023 V&A protest as “a silent protest performance” rather than to conceal her identity, and says SAPS officers observed this without cautioning her (OA §§7–9). She disputes the dating underlying FA §89, saying she was not at the V&A on the date alleged and that the FA’s own annexures are dated months earlier (OA §34), and disputes the FA’s characterisation of the poster addressed at FA §§79–80 — described in the FA as a “Synagogue of Satan” placard — saying it originated from an interfaith poster-making session involving CAYCO, Youth for Palestine and the Anti-Apartheid Art Collective, and that the word “Zio’s” in parenthesis after “Jews” targeted Zionists rather than Jews as a group (OA §§28–31). She also gives a detailed counter-narrative alleging that, after a 16 December 2023 protest outside Zara at the V&A, she and a companion were followed, photographed without consent and verbally threatened (“you are going to jail”) by men she believes were connected to Cape Union Mart security, corroborated by a contemporaneous IOL report of two women protesters being harassed (OA §§13–24), and disputes that the FA’s photographic annexure “C19” was taken “at the event,” saying it was in fact taken at a V&A entrance roughly two minutes’ walk from the Cape Union Mart store (OA §§20–22).
Fifth Respondent (Sayed Ridhwaan Mohamed)
Confirms he displayed a poster including Krawitz’s photograph at the 18 November 2023 Canal Walk protest — captured in annexure “C43,” a screenshot from his own Instagram account, which he says is dated 18 November 2023 and not 31 May 2025 as the FA claims (Mohamed Affidavit [MA] paragraphs [§§] 7–8) — and says a PSC marshal and Chikte asked him and his wife to stop displaying the poster shortly after they arrived, that they complied immediately, and that he has not used that poster since (MA §§9–12). He separately describes being threatened at a 31 May 2025 protest by counter-protesters who told him they were acting on the instruction of “Martine Krawitz (Vogelman),” including a threat to “burn [his] child in a tunnel,” after which he stopped attending PSC protests (MA §§14–16), and argues the interdict sought against him personally is overbroad given that he has since stopped attending and disputes having harmed the applicants (MA §§17–19).
Confirmatory Affidavits (Gamiet, Jeenah, Sylvester, Leith) (deposed November 2025)
Each is a short, formal affidavit — Gamiet and Jeenah deposed 17 November 2025, Sylvester and Leith 18 November 2025 — confirming that the deponent has read and confirms Usuf Chikte’s affidavit “insofar as it relates to me” and supporting the relief sought in it (CA §§1, 4–5). Each declines to disclose a residential address, citing the risk of doxing, harassment and threats from supporters of Israel and Zionism (CA §2); Leith, who is not a named respondent, confirms Chikte’s affidavit generally as the PSC member responsible for demonstrations at Cavendish Mall. None contains independent substantive content beyond this.
4. Centre for Applied Legal Studies — Amicus Curiae Application (Christopher Gevers, 13 February 2026)
Purpose of the intervention and CALS’ interest
CALS, a registered Wits-based law clinic, seeks leave through its Civil and Political Justice Programme (which works closely with the Right2Protest Project) to make written and oral submissions on two narrow issues it says are not otherwise raised by the parties: the line between constitutionally protected speech and hate speech, particularly the history and meaning of “from the river to the sea” (Centre Applied Legal Studies [CALS] paragraphs [§§] 17–18); and the Regulation of Gatherings Act’s section 8 prohibition on face coverings, as applied to religious and symbolic protest attire (CALS §19). It grounds its standing in the CPJ programme’s prior interventions in Right to Know Campaign v City of Johannesburg Metropolitan Municipality and Social Justice Coalition v Minister of Police (CALS §14), and situates the application within the wider context of the ICJ’s provisional-measures findings on Gaza and its Advisory Opinion on the Occupied Palestinian Territory (CALS §§20–23).
Freedom of expression: hate speech and “from the river to the sea”
Drawing on the Constitutional Court’s decision in Masuku,[1] CALS submits the test for whether impugned expression falls outside section 16 protection is objective and contextual: whether a reasonable, informed and objective person would consider it based on Jewish identity and intended to incite harm or propagate hatred (CALS §36, citing Masuku paras 144, 153, 157). Criticism of Israel, the IDF, Zionism and their supporters is presumptively protected speech rather than hate speech, unless contextual factors — such as invocations of Hitler, extermination or the Holocaust — transform it into an attack on Jewish identity as such (CALS §§37–39). Applying the Supreme Court of Appeal’s contextual, non-literal approach in AfriForum v Economic Freedom Fighters to politically charged slogans, CALS submits “from the river to the sea” has no single fixed meaning: it has been used to express Palestinian self-determination, support for a single democratic state with equal rights, or broader calls for liberation, and refers geographically to the territory between the Jordan River and the Mediterranean rather than explicitly identifying a protected group as its target (CALS §§40–44). It follows, on CALS’s submission, that references to Hitler, swastikas, extermination or the Holocaust are not ipso facto antisemitic; whether such references cross into hate speech turns on whether a reasonable observer would understand them, in context, as targeting Jewish identity with intent to incite harm, rather than as directed at Israel, Zionism or the IDF specifically (CALS §§38–39, 68). In support, CALS cites the US First Circuit’s recent decision in Stand With Us Center for Legal Justice v Massachusetts Institute of Technology, which rejected the claim that “from the river to the sea” and accusations that Israel is committing genocide are inherently antisemitic absent supporting facts, while separately noting — via the first-instance decision in Gartenberg v Cooper Union — that the same slogan, rendered in graffiti styled to resemble the font associated with Hitler’s Mein Kampf, was capable of evidencing antisemitic motivation on its particular facts — illustrating, in CALS’s submission, that context and manner of use, not the words themselves, are dispositive (CALS §67).
PSC pamphlets comparing Zionism and Nazism
CALS’ submission is that this comparison is not ipso facto Judeophobic.
Context: historical and contemporary resonance of Nazism and Zionism
CALS’ submission implies that claimed similarities between Nazism and Zionism should be questioned for their historical and empirical accuracy, and not for being Judeophobic.
The right to protest: face coverings, the keffiyeh, and religious dress
CALS submits that reading section 8 of the Regulation of Gatherings Act (RGA) — which prohibits a “disguise or mask or any other apparel or item” obscuring facial features — to categorically prohibit any face covering would hollow out the section 17 right to protest and unjustifiably burden protesters who cover their faces for religious observance, protection from surveillance and reprisal, or symbolic political expression (CALS §§76–77). Invoking MEC for Education: KwaZulu-Natal v Pillay, CALS argues the Constitution protects voluntary as well as obligatory religious and cultural practices, extending this protection to the wearing of a hijab as an expression of religious identity and belief, independently protected under section 15 (CALS §77). It submits that some Seventh Respondent members were seen wearing a keffiyeh — a recognised symbol of Palestinian political solidarity and dissent — and that its use constitutes protected expressive conduct falling within both sections 16 and 17, forming part of the manner in which the right to protest is exercised rather than conduct extraneous to it; the mere fact that a keffiyeh may obscure facial features does not, without more, demonstrate an intention to act violently, intimidate, or evade lawful accountability (CALS §§78–79). CALS supports this with UN Human Rights Committee General Comment №37, OHCHR guidance, the UN Special Rapporteur on Freedom of Peaceful Assembly, and the African Commission’s Guidelines on Freedom of Association and Assembly, all of which recognise a degree of anonymity and face-covering as legitimate expressive conduct during peaceful assembly, restrictable only where necessary and narrowly tailored to a genuine risk of incitement or violence (CALS §§86–94). It submits that section 8 should accordingly be interpreted to accommodate face coverings worn for religious, safety or symbolic reasons, rather than treated as inherently indicative of unlawful intent (CALS §95).
5. Applicants’ Replying Affidavit (Philip Krawitz, 20 February 2026)
Summary response
Krawitz opens by arguing the respondents “admit most of the conduct in question” and that Chikte’s central strategy is to distance the PSC as an organisation from its members’ individual conduct, despite admitting that the PSC organises the events at which that conduct occurs (Replying Affidavit [RA] paragraphs [§§] 5–6). He argues the truth and protected-comment defences both fail on the papers: the respondents do not prove the genocide-funding and child-killing claims true, and where they rely on comment, they neither identify it as opinion rather than fact nor fairly state the underlying facts (RA §§7, 21). He points to a specific evidentiary gap — no averment that Cape Union Mart has ever donated outside South Africa, or that he has raised money for anything other than philanthropic causes (RA §§21.1–21.2) — and argues much of Chikte’s affidavit is inadmissible hearsay and opinion dressed as fact, citing Chikte’s own qualification that his averments rest on “personal knowledge and belief” (RA §§9–10).
Disputed definition of Zionism
Krawitz singles out Chikte’s definition of Zionism — as a movement for a Jewish homeland premised on the exclusion and colonisation of Palestinians and Jewish supremacy — as a contested political claim presented as established fact (RA §§12–13). He says that when the applicants’ attorneys served a Rule 35(12) notice requesting the sources behind Chikte’s footnoted claims, Chikte responded that he had conducted online research and kept no copy (RA §14), and argues this undermines the entire evidentiary foundation of the PSC’s case. In support of his own position, he invokes a joint January 2022 statement by four United Nations Special Rapporteurs (annexure “R1”) cautioning against conflating Zionism with racism (RA §§16–17).
Reply to Chikte (AA)
Persisting with the FA save where the AA’s admissions expressly align with it, Krawitz’s seriatim reply runs RA §§61–473. He argues that even accepting individual posters were not “PSC-produced,” self-identified PSC members who stand behind or distribute such content remain liable, and that Chikte’s disclaimers do not engage with distribution and republication liability (RA §§467–470). On the genocide-funder narrative, he maintains the PSC has shown no link between Keren Hayesod or JAFI and the war in Gaza specifically, as opposed to the government of Israel generally (RA §§46–58), and notes that the public statements the respondents rely on to justify their claims were made roughly a year after the alleged defamation began, so cannot retrospectively justify it (RA §60). He does not take a position on whether Israel’s conduct in Gaza amounts to genocide, framing his complaint as being solely about the attribution of that conduct to him personally (RA §246).
Reply to Ockards (OA)
Krawitz identifies the poster in annexure “C26” as a large, edited image of himself and Netanyahu together, which he says falsely implies a close personal connection (RA §§512–513). On the paragraph disputing dates (FA §89/OA §34), he says the precise date is immaterial because Ockards admits publishing, on her own version, both a manipulated image depicting him with devil’s horns captioned “Killer Way” and “Cape Union Mart,” and a fabricated quotation attributed to him reading “I would be proud to be a bigger donor to Israel (Genocide)” (RA §515.1–515.2), and argues she offers no justification for either (RA §516). On the “Zio’s” poster, he says Ockards does not dispute that she painted an arrow on it pointing toward the Cape Union Mart store, which he says intimates the store’s complicity to an ordinary reader (RA §523).
Reply to Mohamed (MA)
Krawitz denies the allegation that counter-protesters acting on Martine Vogelman’s instructions threatened to “burn [a] child in a tunnel” as vexatious, saying it cannot meaningfully be engaged with as pleaded (RA §538). He encloses a confirmatory affidavit from Vogelman (annexure “R14”) denying that she has ever instructed anyone to protest at Cape Union Mart or made any such threat (RA §539). The replying affidavit closes with the applicants persisting in the relief sought in the Notice of Motion (RA, WHEREFORE clause).
Supporting affidavit of Shlomo Zomer (Keren Hayesod)(24 February 2026)
Deposed by Shlomo Zomer, Chief Financial Officer of Keren Hayesod, sworn 24 February 2026 in Jerusalem and notarised for use in South Africa (cited below as “ZA §”). Zomer confirms his personal knowledge of Keren Hayesod’s dealings with Krawitz and Keren Hayesod South Africa ZA §§1–3 and that he has read Krawitz’s affidavits and confirms their correctness insofar as they relate to Keren Hayesod ZA §4. He explains Keren Hayesod was formed in 1920 and, while recognised as a ‘national institution’ under the Keren haYesod Law-5716, operates independently of the Israeli government and provides it and the Israel Defence Force with no funding whatsoever ZA §§6, 8–9. Keren Hayesod South Africa is not a separate legal entity but a campaign that raises project-specific donations, which are ring-fenced to the donor’s chosen programme and transferred to Keren Hayesod in Israel ZA §§10–16. He lists the only projects Krawitz or Keren Hayesod South Africa have ever supported: the Net@Ramle computer-education project for Arab-Israeli adolescents, the Beit Issie Shapiro therapeutic centre for children with disabilities, the Fund for Victims of Terror (48-hour stipends to terror victims of all backgrounds), the Youth Futures mentoring programme for at-risk Arab adolescents (mainly in Lod), the Barzilai Medical Center in Ashkelon (which serves Arab Israeli and Gazan patients), landscaping for the Karnei Ramon neighbourhood in the Negev, and subsidised housing for the elderly and disabled regardless of religious affiliation ZA §§19–20. Responding directly to the AA, he denies that mechinot leadership programmes involve any military training or Israel Defence Force participation and confirms neither Krawitz nor Keren Hayesod South Africa has ever funded them (ZA §§25–27); denies Keren Hayesod operates beyond the post-1967 borders or has any involvement with the ELAD association, in response to AA §150 ZA §§29–30; confirms an earmarked post-7 October 2023 donation funded flights home for 165 discharged reservists called up for active duty, with no involvement from Krawitz or Keren Hayesod South Africa, in response to AA §153 ZA §§31–32; confirms Keren Hayesod supplies speakers, including former heads of state and Mossad, at donors’ request, in response to AA §154 ZA §32; confirms Keren Hayesod is a 20% stakeholder in the Jewish Agency for Israel, in response to AA §162 ZA §33; and denies Garin Tzabar is a Keren Hayesod or JAFI programme, describing it instead as an Aliyah programme for young immigrants, in response to AA §163 ZA §34.
Supporting affidavit of Moshe Ashirie (Jewish Agency for Israel) (26 February 2026)
Deposed by Moshe Ashirie, Chief Financial Officer of the Jewish Agency for Israel (“JAFI”), with his signature authenticated before an Israeli notary on 26 February 2026 (cited below as “JA §”). Ashirie sets out JAFI’s five areas of work — Aliyah, resilience and connection for Jewish communities worldwide, relief and support for civilians affected by conflict in Israel, and Jewish and Israel education both abroad and within Israel JA §6 — and confirms that, while JAFI is a ‘national institution,’ it operates independently of the Israeli government and provides it and the Israel Defence Force with no funding JA §§7–8. He confirms Krawitz has only ever fundraised for two JAFI programmes: the Fund for Victims of Terror, and the Youth Futures mentoring programme for at-risk Arab adolescents, mainly in the Muslim-Jewish city of Lod JA §11. He details the Fund’s eligibility as extending to any lawfully present civilian harmed in a terrorist incident — Jewish, Muslim, Christian, Druze and Circassian citizens, residents, tourists, migrant workers and Palestinian workers holding valid work permits — while excluding members of the security forces JA §12. He confirms JAFI does not fund, undertake or support settlement activity outside the 1949 Armistice (‘Green’) Line JA §14 and, responding directly to specific AA paragraphs, confirms Keren Hayesod is a 20% stakeholder in JAFI, in response to AA §162 JA §15; denies Garin Tzabar is a JAFI programme, noting JAFI runs its own absorption services, including housing and Hebrew-language classes, for new immigrants, in response to AA §165.1 JA §16; and denies the Fund for Victims of Terror has any Ministry of Defence representation or extends assistance to soldiers, noting it instead includes representatives of the Social Security Institute, in response to AA §165.3 JA §17.
Confirmatory affidavits (Judes, Botha, Vogelman, Sulcas, Spies) (20 February 2026)
Five further confirmatory affidavits, each in near-identical short form, simply adopt the Replying Affidavit’s contents insofar as they relate to the individual deponent, and were all signed on or around 20 February 2026. Adrienne Judes, a retired customer of the Cape Union Mart Waterfront store, confirms the RA insofar as it relates to her and her actions (annexure “R10”) JuA §§1–2, 4. Jacques Botha, Regional Operations Leader of the Cape Union Mart Group, and Simone Sulcas, the Group’s admitted-attorney legal advisor, each confirm the RA insofar as it relates to themselves, their own actions, and the actions of the Applicants’ attorneys of record (annexures “R22” and “R9”) BoA §§1, 3 SuA §§1, 3. Martine Vogelman, the Group’s strategic brands director, gives the same confirmation (annexure “R14”) VoA §§1, 3 — this is the affidavit Krawitz relies on in the RA itself to deny ever instructing anyone to protest at Cape Union Mart or threatening to “burn [a] child in a tunnel” (RA §539). Willem Spies, a director of Hurter Spies Incorporated, the Applicants’ attorneys of record, confirms the RA insofar as it relates to himself and his own actions (annexure “R15”) SpA §§1, 3. All five close by requesting that the relief and prayers in the Notice of Motion be granted.
6. Applicants’ Heads of Argument (9 March 2026)
Relief sought and scope
Counsel frame the interdict narrowly: it targets only the false claim that Cape Union Mart or Krawitz fund genocide or are complicit in killing children, harassment or intimidation of customers, and compliance with the Regulation of Gatherings Act. They stress what is not sought — no restriction on criticising Israel, no bar on assembly or boycott, no hate-speech finding — to pre-empt any framing of the case as an attack on political speech generally.
Defamatory content and liability for publication
The Heads catalogue the specific posters and chants and apply the established two-stage defamation test, arguing the statements are defamatory per se. They then directly rebut the PSC’s central defensive strategy — disclaiming responsibility for content not “PSC-produced” — by invoking republication and distribution-liability principles, and by itemising each individual respondent’s conduct against the Answering Affidavits’ own admissions.
Rebuttal of Defence 1 — Truth and public benefit
The most extensive rebuttal in the Heads. Counsel isolate the “sting” of the allegations and argue the PSC’s factual basis — Krawitz’s roles in Keren Hayesod and the Jewish Agency for Israel — cannot bear the weight placed on it, citing confirmatory affidavits from both organisations’ CFOs denying governmental status or IDF funding, and Cape Union Mart’s own donation records showing no funding outside South Africa.
Rebuttal of Defence 2 — Fair comment
Argues the statements are factual assertions rather than comment, and that even treated as comment, the PSC never disclosed the underlying facts to its audience — a requirement for the defence to succeed — as shown by cross-referencing the PSC’s own acknowledged campaign literature.
Assault on dignity; Regulation of Gatherings Act; requirements for the interdict
Separately from defamation, the Heads argue the devil’s-horns manipulation, the “Synagogue of Satan” poster, swastika displays, and related chants objectively humiliate Krawitz as a Jew. They allege RGA breaches (unnotified gatherings exceeding 15 people, masking, hate symbolism, personally targeted material), and argue the requirements for final interdictory relief — clear right, injury, and absence of an adequate alternative remedy — are met, including for the unidentified sixth respondent class.
7. Respondents’ Application to Strike Out (Usuf Chikte, 20 March 2026)
Nature of the application and applicable principles
The respondents seek an order striking specified paragraphs and annexures from the RA and from the affidavits of Shlomo Zomer and Moshe Ashirie, on four overlapping bases: matter that is scandalous, vexatious or irrelevant under Rule 6(15) (Strike Out Affidavit [SOA] paragraph [§] 6.1); hearsay lacking a proper evidential foundation (SOA §6.2); impermissible new matter raised for the first time in reply, said to bolster and repair deficiencies in the founding papers (SOA §6.3); and undisclosed secondary evidence of disputed documentary facts where the primary sources were available but withheld (SOA §§6.4–6.5). Chikte argues a replying affidavit must be confined to answering the defence raised in the answering papers rather than making out a new case or curing founding deficiencies (SOA §10), and that hearsay, argumentative abuse or matter outside a deponent’s personal knowledge should be struck out or, at least, disregarded (SOA §11). He frames the prejudice as requiring the respondents to meet a materially expanded case for final relief, decided in part on hearsay, anonymous complaints and media reports, that they were never called on to answer (SOA §§7–8, 57–59).
Table A — scandalous or vexatious matter
Chikte tabulates specific RA passages as pejorative abuse rather than evidence: the characterisation of the PSC’s demands as “extortionist and improper” (RA §45.4); accusations that the respondents ran a “dishonest smear campaign” (RA §74) and engaged in “deliberate distortion” (RA §94); the repeated charge that calling the letter extortionist “is no exaggeration” (RA §142); references to the respondents’ “contempt for facts” and that they “mulishly repeat lies” (RA §§222, 226); and further references to a “smear campaign” and “deliberate misrepresentation” (RA §§287, 290). He argues each passage invites the court to decide credibility on insult rather than evidence and causes reputational and forensic prejudice unrelated to resolving the real issues (SOA §§12–13).
New case on attribution of publication
The application’s central substantive complaint is that the RA advances an unpleaded theory of liability. The founding papers pleaded a case about specific publications attributable to identified respondents; in reply, Chikte says, the applicants now contend that because the PSC arranges demonstrations, produces posters, invites the public and later reposts protest images on its own social media, it is legally responsible for defamatory matter “regardless of who held or displayed it” (SOA §§16–18, citing RA §45). He points to the applicants’ further contention that it is “irrelevant” whether the PSC can identify the individuals holding PSC posters, since printing and distributing them means the PSC “quite clearly publishes the defamatory matter” (RA §§162, 164), and to RA §463’s assertion that the PSC cannot distance itself from other protesters’ unlawful conduct merely because they are not PSC members. Chikte argues this is a materially different and broader juridical basis of liability that shifts the case from proof of publication by, or attributable to, specific respondents to organisational responsibility for protest content generally, and that had it been pleaded in the founding papers the respondents could have met it with evidence on the PSC’s organisational structure, authorisation protocols, and the distinction between convening a gathering under the Gatherings Act and publishing in defamation (SOA §§19–21).
New cause of action — online republication, and facts post-dating the proceedings
Chikte separately identifies the applicants’ reliance, in RA §§229–230 and 456, on the PSC’s own Instagram page reposting protest images — including annexure “C11” — as a distinct and previously unpleaded theory that the PSC “republished” all of C11’s content and is thereby independently liable, even though C11 was available to the applicants when they launched the proceedings (SOA §§23–24). He also tabulates fresh material introduced only in reply to expand the case on ongoing harm: October 2025 and January 2026 protest incidents, undisclosed video recordings, an anonymous customer complaint and unnamed “numerous verbal complaints” from shoppers (RA §82, 82.1–82.5); the “Zionist Lawfare Defence Fund” narrative sourced to Mohamed’s Facebook post and a News24 article (RA §§83–88); the Rosengarten narrative concerning a private approach by Martine Vogelman (RA §§130–133); further memorandum correspondence beyond annexures “UC5” and “UC6” (RA §§145–150); and a February 2026 Instagram screenshot of Mohamed’s account (RA §530). Each, he says, post-dates institution of the proceedings or was available at founding stage, and is relied on to expand the injury and final-relief case rather than to reply to the answering affidavits (SOA §§25–27, 29–31).
Hearsay
Chikte argues the clearest hearsay lies in the new complaints material relied on to show ongoing harm: an email from Zuzumuzi Manqunyuana (RA §82.3), an anonymous customer complaint with identifying details redacted (RA §82.4), and unparticularised verbal complaints “laid by shoppers” (RA §82.5). He submits these are advanced for the truth of what the complainants are said to have asserted, without a proper foundation for admission in motion proceedings, and that even a confirmatory affidavit could at best prove a complaint was received, not the truth of its contents — making the anonymous and verbal complaints particularly objectionable (SOA §§28–31).
Zomer’s and Ashirie’s affidavits
Chikte challenges both supporting affidavits as impermissible curative new matter. On Zomer, he targets the boilerplate “personal knowledge” assertion in paragraph 2 and the confirmation clause in paragraph 4 (SOA §37), and, substantively, Zomer’s claim that Keren Hayesod South Africa — not just Krawitz personally — has only ever funded charitable projects (paragraphs 19–21), arguing this exceeds the applicants’ pleaded case that only the second applicant himself donated exclusively to charitable causes, and is unsupported by any disclosed underlying records (SOA §§39–43). He raises the same objection to Zomer’s account of JAFI’s Lone Soldiers programme and the mechinot programme (paragraphs 22–27), Zomer’s ELAD-association denial (paragraph 30), and his denial of funding for the post-7 October reservist airlift (paragraph 31, last sentence), on the basis that Zomer, as Keren Hayesod’s CFO, provides no factual basis or documentary support for his assertions beyond an unexplained claim of personal knowledge (SOA §44, 46–51). On Ashirie, Chikte raises the equivalent objection to the boilerplate paragraphs 2 and 4, and to the substantive claim in paragraph 11 that Krawitz’s JAFI fundraising was confined to only two programmes, arguing it too was aimed at buttressing the applicants’ core “benign projects only” contention and should have been pleaded in the founding affidavit, together with the related assertion in paragraph 14 (SOA §§52–56).
Prejudice and relief sought
Chikte concludes that if the impugned matter remains on record, the respondents will be required to meet a materially expanded final-relief case never made in the founding affidavit, the applicants will have used reply to repair founding deficiencies contrary to settled motion procedure, the court will be invited to decide central issues on hearsay, anonymous complaints and media reports, and the respondents will suffer reputational and forensic prejudice from repeated accusations in reply that they are dishonest, vexatious, antisemitic or extortionate — prejudice he says cannot be cured merely by argument at the hearing, because the impugned matter shapes the evidence and the lens through which the court approaches publication, wrongfulness and final relief (SOA §§57–61). The respondents accordingly seek an order in terms of the notice of application — striking the passages identified in Tables A and B, together with the identified paragraphs of the Zomer and Ashirie affidavits — with costs against the First and Second Applicants (SOA §62, and the Notice of Application prayers 1–3).
8. Respondents’ Heads of Argument (20 March 2026)
Overview and structure of the argument
Counsel frame the application as one for a final interdict on motion, subject to the heightened Plascon-Evans threshold and the exceptional caution attaching to prior restraint of speech (Respondent Heads of Argument [RHoA] paragraphs [§§] 1, 9–12). They deny the campaign is motivated by antisemitism, characterising it instead as a socio-political boycott rooted in South Africa’s apartheid history and moral outrage at what they describe as a plausibly genocidal campaign in Gaza, and argue Krawitz is targeted for his leadership roles in Israel-linked fundraising and governance bodies rather than for being Jewish (RHoA §§7–8). The argument proceeds in four stages: preliminary objections (unclean hands and strike-out); Plascon-Evans and the applicants’ inability to prove publication or attribution; a differentiated, statement-by-statement analysis of meaning and defences; and the overbreadth of the individual prayers (RHoA §21).
Unclean hands (in limine)
The respondents argue the FA presents a misleading, selectively curated narrative: it omits that the protest coalition included CAYCO, BDS, the Cape Town Intifada, Mothers for Gaza and South African Jews for a Free Palestine, not just the PSC (RHoA §27.1); omits the 13 December 2023 memorandum exchange showing Cape Union Mart engaged with the PSC’s political demands as such (RHoA §27.2); highlights Krawitz’s own admission that he chose whom to sue based on “optics,” avoiding “Jew versus Jew” (RHoA §27.3); and says the FA understated Krawitz’s Israel-linked roles, omitting his JAFI Board of Governors seat, and mischaracterised Keren Hayesod as a mere “non-profit,” omitting its ties to the Israeli state and IDF (RHoA §§27.5–27.6). They note the Applicants’ Heads do not engage this objection at all (RHoA §31) and press for dismissal on this basis alone (RHoA §30).
Strike-out application
The Heads incorporate and expand the strike-out application summarised in Section 6, adding case-law support (Pilane; Mistry) for the rule that an applicant “stands or falls” by its founding affidavit (RHoA §35), and arguing the Zomer and Ashirie affidavits are, at best, weak secondary evidence of undisclosed underlying records, entitled to little weight under Gemeenskapsontwikkelingsraad v Williams and Manwadu (RHoA §§45–52).
Plascon-Evans and material factual disputes
The respondents catalogue eleven disputes said to be individually dispositive on motion (RHoA §61.1–61.11), including whether “the PSC” can be treated as a single publisher given the multi-organisational protest environment, whether Ockards or Mohamed personally published any statement relied on, the applicants’ own concession that it has “never been possible … to discern” who is a PSC member, the proper meaning of slogans such as “funds genocide,” and whether Cape Union Mart has shown any quantifiable commercial harm, having refused Rule 35 discovery of its financial records.
Publication and attribution
This is treated as a threshold requirement the applicants cannot meet. The respondents argue the RA impermissibly shifts from a case about specific, identified publications to a broader “organisational responsibility” theory — that the PSC is liable for any protest content merely by convening, printing posters, or reposting images online — contrary to Theletsane’s rule against introducing a new case via reply (RHoA §§66–70). They invoke NEHAWU v Tsatsi and Moyane v Lackay for the proposition that republication or use of an organisation’s material by others does not, without more, fix the organisation with liability, and Du Preez v Minister of Police as a close analogy where attribution was refused for want of proof (RHoA §§75–80). They separately argue the Gatherings Act’s convenor-responsibility regime is a distinct legal inquiry from defamation publication and cannot substitute for it (RHoA §§73–74).
Cape Union Mart’s separate position
As a trading corporation, Cape Union Mart is said to be incapable of claiming dignity protection, only reputation, and Reddell is invoked for the proposition that where speech concerns public-interest discourse, the constitutional balance “shrinks dramatically” against reputational protection and general damages “may not be considered” (RHoA §§82–86). Its case is also said to be entirely derivative of the case against Krawitz personally.
Meaning, wrongfulness, and the defences
The respondents argue protest slogans must be read contextually and impressionistically, not literally — “funds genocide” and “kills babies” are political condemnation and hyperbole, not factual accusations of personal wrongdoing (RHoA §§91–94). They differentiate their defences by statement: truth/public benefit is strongest for statements linking Krawitz to Israel-linked institutions generally (RHoA §104.1), while protected comment is strongest for the more compressed slogans (RHoA §104.2). On truth, they rely heavily on Keren Hayesod’s own published materials — its 2023 Impact Report and UIA articles on the Lone Soldiers and Mechinot programmes — quoting language describing the Mechinot as preparing youth “for acceptance to higher-level IDF units,” and argue the applicants misquoted the Lone Soldiers material by omitting that support continues during active service, not only after discharge (RHoA §§127–133). They also invoke a 2019 Canadian Revenue Agency finding revoking a charity’s status for funding a Mechina, as documentary support that such funding assists the IDF (RHoA §§135–141). They argue the applicants’ new “ring-fenced, charitable-only” narrative, advanced via the Zomer and Ashirie affidavits, was improperly introduced only in reply and remains, at best, weak secondary evidence given the absence of primary records (RHoA §§142–151).
Prior restraint jurisprudence and comparative foreign authority
The respondents situate this case with Herbal Zone, Tau, and Malema v Rawula — all cautioning against sweeping, anticipatory speech restraints and favouring a damages action where facts are disputed — distinguishing it from EFF v Manuel on the basis that the relief here is open-ended and the facts are genuinely contested (RHoA §§152–166). A substantial section surveys UK (Campaign Against Antisemitism v DPP; Greenstein; Ware v Waters; Husain v SRA), US (Stand With Us v MIT) and ECtHR (Baldassi v France) authority for the propositions that protest meaning is contextual, that anti-Zionist or anti-Israel speech is not automatically antisemitic, and that boycott advocacy is core protected political expression (RHoA §§167–181).
Application to the specific prayers, and costs
Each prayer in the Notice of Motion is challenged individually as unsupported, overbroad, or resting on disputed facts — including prayer 1.7 (any “defamatory statements”) as impermissibly vague, and prayer 1.9 (Sheriff/private security enforcement) as disproportionate (RHoA §§186–189). The respondents dispute the Gatherings Act basis for prayer 1.8 subsection by subsection (RHoA §187) and conclude the application should be dismissed with costs (RHoA §§193–194).
Conclusion
The Applicants’ and Respondents’ themes are juxtaposed below without adjudicating between them, followed by an identification — not itself an adjudication — of the point on which their positions most directly collide. The court, having heard argument on 15, 17 and 18 June 2026, will resolve them.
The Applicants’ themes
Krawitz and Cape Union Mart maintain that neither has any institutional link to the Israeli state or its military, and that Krawitz’s fundraising for Keren Hayesod and the Jewish Agency for Israel — confirmed by both organisations’ Chief Financial Officers — is confined to humanitarian, cross-community causes such as the Fund for Victims of Terror. On this basis they argue the protesters’ central claims, that the Applicants fund genocide or are complicit in killing children, are not true, are not fair comment on a fairly stated set of facts, and are therefore defamatory rather than protected political speech. They further argue that specific material — swastika imagery, the “Synagogue of Satan” placard, a devil’s-horns manipulation of Krawitz’s photograph — targets Krawitz because he is Jewish, causing a distinct injury to dignity, and that the PSC cannot escape liability for content it did not personally produce given its role in organising, printing, distributing and reposting it. They frame the interdict sought as narrow: confined to the genocide-funding and child-killing claims, harassment, and compliance with the Regulation of Gatherings Act, and not a restriction on criticising Israel, a ban on boycotts, or a hate-speech finding.
The Respondents’ themes
The PSC and the individual respondents characterise the boycott as a lawful, non-violent political campaign protected under sections 16 and 17 of the Constitution, targeting Krawitz’s leadership roles in Israel-linked fundraising and governance bodies rather than his Jewish identity as such. They argue those roles substantiate, rather than defame, the contested characterisations, and that slogans such as “funds genocide” and “kills babies” are political condemnation and hyperbole to be read contextually, not literal factual accusations. They contend the Founding Affidavit presents a selectively curated narrative — omitting the other organisations involved in the protests and Krawitz’s own account of choosing whom to sue based on “optics” — and that the Replying Affidavit impermissibly advances a new, broader theory of organisational liability that was never pleaded in the founding papers. On the Gatherings Act, they argue face coverings worn for religious observance or symbolic protest, including the hijab and the keffiyeh, are protected expressive conduct rather than evidence of unlawful intent — a position the CALS’ amicus submissions also advance — and situate the interdict sought within a wider body of South African and comparative jurisprudence counselling particular caution before restraining political speech in advance.
The central point of division
Running beneath the doctrinal disagreements set out above is a single contested question on which the outcome most plausibly turns: whether Krawitz’s leadership roles in Keren Hayesod and the Jewish Agency for Israel can be reconciled with his claim that his fundraising through them is confined to neutral, ring-fenced humanitarian work. The Applicants’ case for relief depends on establishing that the “funds genocide” and “kills babies” characterisations are false — that, as Krawitz, Zomer and Ashirie depose, his institutional roles are genuinely separate from Israeli state or military activity, leaving the statements without factual foundation and therefore defamatory rather than fair comment. The Respondents’ answer is that this claimed separation is illusory: that leadership of bodies which fund a Mechina, hold a 20%-stakeholder relationship with each other, and operate, on their own evidence, independently of but still deliberately proximate to the Israeli government and its military, cannot honestly be called neutral. Their argument operates on two levels at once — a factual claim that these institutions materially support Israeli state and military activity, and a more interpretive claim about what complicity itself means, namely that claiming institutional neutrality in these roles is not a defence to that charge but the very mechanism by which such support is normalised and shielded from criticism. That second, definitional layer is harder to resolve simply as true or false than the first. Because this dispute sits at the evidentiary core of the truth and fair-comment defences, and because these are motion proceedings in which a genuine, non-fictitious dispute of fact is ordinarily resolved in the Respondents’ favour on the papers, it is arguably this question — more than the disputes over attribution, Gatherings Act compliance, or the Setlogelo requirements — that will determine how the court rules.
The pending judgment
All hyperlinked papers to one of my websites, are currently available on CaseLines — the Founding Affidavit, the Answering Affidavits, the CALS amicus curiae founding affidavit, the Replying Affidavit and its supporting/confirmatory bundle, the Respondents’ Application to Strike Out, and both parties’ Heads of Argument — have now been incorporated in full. Whether CALS’s substantive written and oral submissions (as opposed to its application for admission) were in fact filed and argued at the June 2026 hearing has not yet been established from the papers reviewed. The Respondents’ Heads of Argument were filed with the matter on the roll for 4 and 5 May 2026, but the hearing was in fact held over three days before a full bench (Cloete, Barendse and Nziweni JJ) on 15, 17 and 18 June 2026, with judgment reserved on 18 June. This document will be updated once judgment is handed down.
Paul Hendler, Stellenbosch, South Africa
16 August 2026
Author’s Declaration
I was assisted in preparing this document by Claude, an AI assistant made by Anthropic. I checked every affidavit and document reference in the body of the text against the underlying source documents. Any errors that remain are my own.
References
[1] See my article ‘Constitutional Court’s erroneous signification of antisemitism’, which draws a similar conclusion to CALS about this case, but unlike CALS is openly critical of the illogicality of the Constitutional Court’s decision.
[2] Arendt, H 1977 Eichmann in Jerusalem: A Report on the Banality of Evil, pp. 40–41; and, page 42.
[3] Davidowicz, 1976 L A Holocaust reader, pp. 150–153.
[4] Black, E 1984 The Transfer Agreement — The Untold Story of the Secret Pact between the Third Reich and Jewish Palestine.
[5] Braham, R 2000 The Politics of Genocide; and, Greenstein, A 2019 Randolph Braham, Rudolf Kasztner and the Auschwitz Protocols (blog).
[6] Times of Israel, 2023 Ex-IDF general likens military control of West Bank to Nazi Germany.
[7] Resource 1 UK (undated) ‘Death to the Jews’ (blog).
[8] World Peace Foundation, 2025 Famine Crimes in World War Two: The Warsaw and Łódź Ghettos.
[9] The National World War II Museum, 2023 The Exterminationist Mindset: Heinrich Himmler’s October 1943 Speeches.
[10] Wikipedia, (undated) ‘Death to Arabs’.
[11] Gritten, D 2025 Gazans ‘wasting away’ as mass starvation spreads, humanitarian groups warn, BBC.
[12] Wikipedia, (Undated) Yoav Galant.
[13] Middle East Monitor, 2024 ‘The basic rule we have when fighting in the holy war: Do not spare any soul’.
[14] Levy, D 2023 X post by IOF soldier.
[15] Baroud, R 2023 Opinion — Israel’s twisted logic makes the murder of Palestinian children a matter of state policy, Middle East Monitor.
[16] Wikipedia, (undated) Ingrid Olderock.
[17] Jones, O (undated) Battle Lines; Carrol, J 2025 Israeli Prison Guards Are Using Dogs to Rape Palestinians, Former Detainees Say, Novaramedia; UN HR Office of High Commissioner, 2024 Israel’s escalating use of torture against Palestinians in custody a preventable crime against humanity: UN experts (reporting on Torture and sexual violence in Sde Teiman prison); and, Gritten, D 2025 UN experts accuse Israel of sexual violence and ‘genocidal acts’ in Gaza, BBC (which refers specifically to ‘severe mistreatment of Palestinian detainee at Sde Teiman’)