On 30 August 2013, the 33 residents of Ekuthuleni shelter, relocated after the landmark Blue Moonlight judgment, filed their replying affidavits in the Dladla application. This application is essentially about whether the City of Johannesburg (and Metropolitan Evangelical Services, which runs the shelter on the City's behalf) can lawfully and constitutionally evict the residents from the shelter without a court order; apply a gender-differentiation rule so rigidly as to split residents up from their spouses, partners and children; and lock everyone out of the shelter during the day.
This main affidavit by Paul Maobelo refers to two supporting affidavits which interrogate some of the key aspects of the City and MES' opposition to the application. The first affidavit - by Garth Stevens, a clinical psychologist and associate professor at the University of the Witwatersrand - deals with the regime enforced at Ekuthuleni and its appropriateness as part of an intervention intended to assist recently evicted and relocated people. He concludes that "the daytime lockout rule, the gender-separation rule and the time limitations placed on the residents at the Ekuthuleni shelter are harmful to the residents’ psychological well-being, corrosive of their self-respect and dignity and unlikely to empower them to find their own accommodation within six or twelve months, or at all." The second affidavit - by Lauren Royston, a development planner and informal housing specialist - investigates the availability of low-cost rental housing in Johannesburg for people in the financial position of the residents. She concludes from her research that "there is no accommodation other than the shelter which is practically available and accessible to the residents at present. Without a fundamental change in the structure of the rental housing market...this is unlikely to change in the foreseeable future."