TAKE NOTICE THAT an URGENT CHAMBER APPLICATION is hereby made for an Order in terms of the Draft Order annexed to this Application on the grounds that:

1. The constitutional rights of the Applicants and all those on whose behalf they bring this application, including the rights of minor children, are under imminent threat as a direct result of the appeal by the First Respondent against the order of this Honourable Court in Case No. HC 263/18 which suspends the operation of that order and strips children and teachers of the protection granted to them by this court leaving them vulnerable to political exploitation by the Respondents.

2. In HC 263/18, the Court granted interim relief to the Applicants interdicting and restraining the First Respondent from doing any of the following activities:
   1. Asking, encouraging or forcing children at schools to attend its political rallies or causing the closure of schools for its political rallies;
   2. Compelling teachers to attend its political rallies, wear party regalia, prepare performances for school children to deliver at political rallies, or making financial contributions towards rallies;
   3. Using school property including school premises, buses and furniture for its political rallies.

Additionally, Second Respondent, who abided by the court’s decision, was interdicted and restrained from assisting the First Respondent to do any of the restrained activities.