IN THE REGIONAL COURT FOR THE REGIONAL DIVISION OF GAUTENG

(HELD AT PROTEA)

CASE NO:

In the matter between

SBONELO GODFREY MKHIZE

JOHN KOKOSI MOFIKENG APPLICANT

AND

THE STATE RESPONDENT

________________________________________________________________________

AFFIDAVIT IN SUPPORT OF BAIL APPLICATION

________________________________________________________________________

I, the undersigned;

SBONELO GODFREY MKHIZE

Hereby state under oath that:

I am the applicant in the above mentioned matter.

2
I am a 26 Year old male South African citizen born on the 26 th February
1990 with ID NO: 9002085407085. I was born at Zola clinic in Soweto
in Gauteng Province. I am currently staying at house no 938 Rasemela
street Zondi 1 in Soweto with my Mother, sister and four brothers. I
have been staying at the above mentioned address since I was born.

3
I completed school in 2009 at Litary Secondary School in Jabulani,
Soweto where I passed grade 12. Before I was arrested I was employed
by my father at his scrabyard selling second hand car parts. I was
earning an amount of R1200-00 per month.
I am not married but I have two children a boy and the girl who are
twins and are two years old. They are staying with their mother and I
am supporting them financially.

I do not possess passport and have no connections or financial means

to flee from the Republic of South Africa where my entire family lives. I
have not previously travelled or resided in foreign countries and have
neither assets outside the Republic of South Africa. I do not own any
immovable property.
5

I have no pending criminal cases against me for which I am out on bail.

I have no previous convictions and no warrants outstanding against
me.

In the present matter, I am charged with the following charges;

6.(1) .
6.(2)
6.(3)
I intend to plead not guilty to all the charges and readily believe that
my defence to these charges will be successful at the trial stage, I was
advised that this is a schedule 5 offence and I need to adduce
evidence which satisfy the court that it is in the interest of justice that I
should be release on bail.
I was arrested on the 05th of December 2016. On the day of my arrest I
was at home with my family. The police came and they told me that I
robbed the complainant using the fire-arm. They searched my place
but could not find the said fire-arm. I respectfully submit that the state
does not have a strong case against me.

I intend to stand my trial if I am released on bail. Functioning of

criminal justice will not be placed in jeopardy due to my release on
bail. I pose no danger to public safety or individual safety.

8
In order to prepare for my trial I need to consult with my Counsel and
this is impossible in the conditions that prevail in the prison. I will be
severely prejudiced in preparation for my trial should bail be refused.
I humbly submit that the interest of justice do not require that I remain
in custody pending the final outcome of my trial which may take
months as a result of congested criminal rolls of our Honourable
Courts.

9
Should the Honourable Court grant me bail my family can afford to pay
an amount of R.. readily available.
WHEREFORE I pray that it may please the Honourable Court to grant
me bail.

____________________
DEPONENT

SIGNED AND SWORN to before me at Protea on this the ..day of

December 2016, by deponent who has acknowledged that he knows
and understands the contents of this affidavit, that he has no objection
to taking the prescribed oath and that he considers the same to be
binding on his conscience.

__________________________
COMMISSIONER OF OATHS