This is without doubt an extraordinary matter.  It arises out of VAT fraud committed on a grand scale against the South African Revenue Service (SARS) causing it to suffer a huge loss. It is common cause that the fraud was perpetrated (rather shamelessly I may add) by a certain Petrus Johannes Uys Badenhorst (‘Badenhorst’) who, at all material times, traded as SA Global Trading (‘SA Global’).  Badenhorst is not a party to these proceedings and as such no relief is being sought against him in spite of the fact that he is indebted to SARS in an amount exceeding R800 million. He is currently insolvent and there is no hope of SARS recovering any amount from him.