Pleadings are intended, amongst other things, to identify the nature and parameters of a dispute.  Care must be taken at the time of drafting to ensure that the full ambit of a party’s case is canvassed.  In the case of the review application an applicant has the added advantage that a weak founding affidavit can be completely replaced or augmented by a supplementary affidavit.  It is at that point of the applicant’s preparation of the application that it must focus its mind on the merits of its case.  It should not regard the supplementary affidavit as merely a preliminary exploration of issues to be more fully developed when heads of argument are prepared.  Still less should it consider the supplementary affidavit as anything less than its final statement of its grounds of review.  There may be exceptional circumstances where issues come to light that a party exercising reasonable diligence in the preparation of their case could not have been aware of, or where there is some other justifiable reason why a material issue is omitted.  

Lagrange J in Bafokeng Rasimone Platinum Mine (Pty) Ltd v CCMA (JR2296/12) [2015] ZALCJHB 198 (8 July 2015) at para [5].