In terms of Section 7(1) (a) of the Criminal Procedure Act, 1977, Supreme Court of South Africa while deciding upon the constitutionality of Section 7(1) (a) of the Criminal Procedure Act, 1977 held that only private persons are allowed to institute private prosecutions and not juristic persons;
It also dealt with the aspect as to whether the differentiation is rational and connected to a legitimate governmental purpose, [National Society for the Prevention of Cruelty to Animals v. Minister of Justice and Constitutional Development (20781/2014) ZASCA 206, decided on 04.12.2015]
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