It is further submitted that the second respondent's letters tb the applicant purporting to demand from the latter apologies were iisued without the authority to do so. The cumulative effect, it is submitted, is that the applicant was not given the right to be heard as the letters requiring it to offer explanation or apology were written lj>y an unauthorized person. The other ground raised under paragraph 13 of the affidavit but disputed in the counter this I court 10) is that affidavit ( paragraph (Bongole J) has previously issued an order restraining the Minister for Information Culture Sports and Arts and the Registrar of Newspapers from interfering with the activities of the applicant. Mr. Matagane learned Senior State submissions of the applicant's counsel Attorney countered! by submitting the that the I first respondent has the authority to ban the Newspaper because section 4 of the interpretation of Laws Act, Cap 1 defines a Minister to iticlude a Deputy Minister. The learned Senior State Attorney invited thd court to find no merits in the applicant's argument that the Deputy banister (first respondent) acted ultra vires. As hearing, for that the applicant the second ground was denied Mr. Matagane submitted that he was given one and a Indeed wrote a letter of apology as stated under paragraph 3 of the counter affidavit. On the submission authority to demand that the second respondent Had no explanation or apology from the applicant! . it is submitted that the said second respondent being the secretariate 1 of the 3

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