Ritcher v Absa Bank Limited (20181/2014) [2015] ZASCA 100 (1 June 2015) per Dambuza AJA (Mhlantla, Leach, Pillay JJA and Fourie AJA concurring):

SCA Summary: Business rescue – application for business rescue can be made after final order of liquidation – Interpretation of ‘liquidation proceedings’ in s 131(6) of the Companies Act 71 of 2008 – ‘liquidation proceedings’ includes court proceedings and the complete process of winding up or liquidation of a company.