The requirement that a body outside executive control is what is being ordered is clear. In Glenister Three, the court doubled down on the notion of an adequately independent (in the sense explained above) anti-corruption body. There is international controversy around the clashes between the multi-agency approach favoured by NACS and NACAC and the single-agency approach of our highest court. To the extent that the NACAC report does not reflect a constitutionally pure approach, the executive should approach its recommendations with caution. He took silk in 1995 and acted on the Cape Bench at the invitation of three successive judges president.