Reverend Llewellyn Joseph and Dr Allen Joseph of Revival Ministries are being represented by the Hindu Dharma Association of South Africa for distributing a video containing hate speech against Hindus. The law firm outlines the background of the case, definitions of hate speech in South African law, and violations of the constitution. They request a written undertaking from Revival Ministries to refrain from such speech and propaganda against Hindus. Failing this, they will pursue legal relief including an interdict, damages of R1 million, and potential criminal charges.

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Our Ref: Ms Ntombi Dladla/SR/ S637.1
Your Ref: Rev Joseph
Date: 17JUNE 2020
TO: Reverend Llewellyn Joseph
TO: Dr Allen Joseph
TO: Revival Ministries
16 Ruby Centre
Croftdene
Durban
Email: info@revivalministries.co.za
RE: HINDU DHARMA ASSOCIATION OF SOUTH AFRICA // REVEREND
LLEWELLYN JOSEPH, ALLEN JOSEPH & REVIVAL MINISTRIES
We act for the Hindu Dharma Association of South Africa, in this class
action/application suit that shall also include an alliance of Hindu Organizations.
We are instructed as follows:-
Background
1. On or about 3 February 2020, THE Revival Ministries, represented by Reverend
Llewellyn Joseph and Dr Allen Joseph acting in concert, distributed a video on
Facebook wherein your Reverend Llewellyn Joseph makes the following
statements:-
“The fear, that that curse or those spirits are working in and through your home, and
every time when it comes along that Kavadi time, the previous time, you just feel the
heaviness come upon your family and your home”
2. The aforesaid video received widespread negative media coverage and backlash
from the public.

2. 3. The factual matrix of the aforegoing are all within your own knowledge and same
shall be set out in detail upon our client seeking the appropriate relief inter alia in:-
3.1. the Equality Court of South Africa,
3.2. the South African Human Rights Commission
3.3. in the High Court of South Africa, namely a class action for damages
3.4. the Commission for the Promotion and Protection of the Rights of Cultural,
Religious and Linguistic Communities (CRL),
3.5. A complaint to the South African Police
3.6. We are instructed to annex hereto, marked Annexure A, an extract of an
academic textbook on Hindus namely, “Inside Indian Indenture” by Professor Ashwn
Desai and Professor Goolam Vahed (Unisa Press 2010), which speaks for itself.
3.7. We are instructed, inter alia, to discover this as evidence against you and your
organization that highlights your hate speech herein.
Legal Submissions
4. Hate Speech is defined in our Constitution of the Republic of South Africa Act 108
of 1996 as follows:-“advocacy of hatred that is based on race, ethnicity, gender or
religion, and that constitutes incitement to cause harm”
5. It is clear that the aforesaid utterances by your Reverend Llewellyn Joseph
amount to hate speech.
6. Hate Speech is prohibited in terms of section 16(2) of our Constitution and is
furthermore prohibited in terms of section 10 of the Promotion of Equality and
Prevention of Unfair Discrimination Act No 4 of 2000.
7. The Hindu Community, including our clients’ have the aforementioned right to
equality as guaranteed in section 9 of the Constitution, Act 108 of 1996 may well
have been violated by your conduct and vicious utterances herein.
8. Our client further instructs us that your offending conduct falls within the purview
of s 10, 11, and 12 of the Equality Act, and having regard, objectively, to all the
relevant circumstances and its proper context.
9. Client has requested that we point out to you that aforegoing conduct has the
propensity to escalate to protesting, riots or inter religious / ethnic discord that may
reveal same to be a threat to public safety.

3. 10. Needless to say, your aforesaid verbal conduct or harassment aimed at the
Hindu Community as set out above has caused the Hindu community and our client
personal harm, mental and psychological pain.
11. Our purpose in writing to you is to request that you immediately issue a written
and irrevocable undertaking in which your organization and representatives declare
that you shall forthwith refrain from the aforesaid conduct uttering negative, hateful
and hurtful statements relating to the Hindu religion, faith, practices and community
in its entirety.
12. In the interim our client firmly instructs us to pursue and obtain the necessary
relief/damages against you and your organization notwithstanding you providing us
with an undertaking in writing that you shall refrain from the aforesaid conduct.
13. We wish to politely point out that we are instructed to obtain the following relief in
the Equality Court/Human Rights Commission/CRL :-
13.1. That you and your organisation be interdicted and restrained from insulting,
harassing, propagating hate, degrading the Hindu Community and from
publishing, propagating, advocating or communicating hate speech as defined
in section 10 of the Equality Act in any form whatsoever on any public/social
media forum.
13.2. The payment of damages in the sum of R1 000 000 (One Million Rands) as an
award jointly and severally the one paying the other to be absolved, as
contemplated in section 21(2)(e) of the Equality Act to be payable to the
“Oliver and Adelaide Tambo Foundation” (OATF) or a Hindu Religious
Public Benefit Organisation of our client’s choice, for the promotion of non-
racialism, tolerance, reconciliation and social economic upliftment in South
Africa.
13.3. That the clerk of the Equality Court be directed to submit this matter in its
entirety to the Director of Public Prosecutions KwaZulu-Natal for consideration
regarding the institution of criminal proceedings, either in terms of the common
law or relevant legislation.
13.4. You and your organisation shall be jointly and severally liable for all costs
herein.

4. 14. Kindly note that our instructions are also to forward a copy of this letter to the
Human Rights Commission and the CRL of South Africa and Facebook as
interested parties.
Our client hereby declares the Hindu Community’s constitutionally guaranteed rights
to dignity, equality, freedom of belief and freedom of religion and reserves its right to
seek the appropriate relief with regard to having these rights protected by the above
forums.
All our clients’ rights are reserved.
Kindly acknowledge receipt hereof.
Thanking you for your co-operation hereof.
Yours faithfully
PER SHAMINDER RAMPERSAD
SHAMIN RAMPERSAD AND ASSOCIATES
CC: THE SOUTH AFRICAN HUMAN RIGHTS AND COMMISSION
PER EMAIL: Kboyce@Sahrc.Org.Za
CC: FACEBOOK LAW ENFORCEMENT SYSTEM
PER FACEBOOK FORUM
CC: COMMISSION FOR THE PROMOTION AND PROTECTION OF THE RIGHTS
OF CULTURAL, RELIGIOUS AND LINGUISTIC COMMUNITIES
PER EMAIL: maureen@crlcommission.org.za