Braddrick Investments v The Attorney General (2021/HP/0728) [2025] ZMHC 132 (31 December 2025)

IN THE HIGH COURT FOR ZAMBIA AT THE PRINICPAL REGISTRY HOLDNE AT LUSAKA (CIVIL JURISDICTION) BETWEEN: 2021/HP/0728 BRADDICK INVESTMENTS LI PLAINTIFF AND THE ATTORNEY GENERAL EFENDANT Before: The Hon. Mr. ~T....::A_,'f',.,.•, ----- ulu For the Plaintiff Mr. P. K. Chibun _____ r. ___ Messrs Mosha and Comp any. For the Def endant: Mr. K. Chipulu, Assistant Senior State Advocate, Attorney General's Chamber. JUDGMENT Cas e re ferred to: 1. Hadley v Bexendele [1854] 9 Exch 341). 2. Kapwepwe v Zambia Publishing Company Limited ( 1987) Z. R. 15. 3. Attorney General v Martha Mwiinde (19870 Z. R. 71. 4. D. Landless v Attorney General(l970) Z. R. 50. 5. Beaudesert Shire Council v Smith(1966) 120 CLR 145. 6. Northern Territory of Australia v Mengel, Arthur John and Others ( 1994) 95 NTR 8. 7. AB and Other v South West Water Services Ltd {1992] 4 All E. R. 588. 8. Martin Nyandoro v Attorney General (1979) Z. R. 276. Legislation referred to: 1. The State Proceedings Act Chapter 71 of the Laws of Zambia. 2. Forestry Act No. 4 of 2015. __ .. 1.0 INTRODUCTION 1.1 The Plaintiff, Braddick Investment limited took out the present action via a writ of summons and statement of claim dated June 24, 2021, against the Attorney General seeking the following reliefs: i. the sum of K37,875.00 being the cost incurred to obtain production licenses; ii. the sum of K250,000.00 being the cost incurred to identify appropriately sized trees and log the chosen trees; iii. the sum of USD 175,000.00 potential income and interest for the business venture; and iv.general and exemplary damages; 1.2 The Attorney General entered appearance and defence on August 9, 2022, and denied the Plaintiffs claims. 2.0 THE PLAINTIFF'S CASE 2.1 For the Plaintiff, Mr. Mubanga Stanley Kapilima testified in his capacity as the Managing Director in the employ of Plaintiff Company. He relied on his witness statement and bundles of documents. 2.2 He said on December 8 , 2016, his company, was granted a Forest Concession Licence FCL No. 037. He said the licence allowed the Plaintiff to engage in timber cutting and processing within Chinakila Open Forest in Mpulungu District. He recounted that on January 16, 2017, the Plaintiff was issued with a Production Licence No. 305365, valid for one month, which permitted the lawful harvest of 101 cubic meters of -J2- Mukula trees. He said the requisite fee of ZMW 37,875.00 was paid to the government. 2.3 He added that in compliance with the Production Licence, diligent steps were taken to identify appropriately sized trees within the licensed area, Chinakila Open Forest. He said preparatory works led the Plaintiff to incur expenses in the sum of ZMW 250,000.00. He stated that the Plaintiff managed to cut a total of 105.69 cubic meters of Mukula logs, as indicated in the Log Harvest Tally Sheet. 2.4 He said before the Plaintiff could fully benefit from the Production Licence, the Plaintiffs operations were abruptly disrupted. He narrated that the District Commissioner (DC) for Mpulungu District along with some other government officials and security personnel swung in action and seized the harvested Mukula logs stacked at the Plaintiffs designated site. He said apart from the seizure, the Plaintiffs employees were wrongfully arrested under false accusations of possessing illegally harvested Mukula trees. That this prompted the Plaintiff to complain to the Director of Public Prosecutions in a letter dated March 24, 2017, over prolonged detention of its employees. 2.5 He said the case against the Plaintiffs employees was later dismissed, leading to their acquittal. 2.6 He said in order to resume their operations, the Plaintiff promptly applied and obtained Conveyance Lice nces No. -J3- 326106 and 326107 from the office of the Kasama District Forestry Office on April 28, 2017, accompanied by requisite fees of Kl,200.00. He said despite fulfilling all the necessary requirements, the District Commissioner (Mpulungu) obstructed their business operations, by frustrating the hammer marking of the logs: reported to be a crucial process/requirement specified by the Conveyance Licence. He said this obstruction significantly curtailed the Plaintiffs ability to move the logs and consequently disrupted the Plaintiffs operations. 2.7 He said the Plaintiff Company suffered significant losses. According to him, the Plaintiff did not only lose the felled, processed and mopped logs that were ready for transportation, but was equally unable to fulfill its contractual obligations to its customers. That its customers had agreed to purchase 101 cubic meters of timber for US$ 175,000.00 in accordance with their contractual agreements and business projections. In support, he referred to two contracts allegedly made between the Plaintiff and its clients, reported to have been unfulfilled. 2.8 In cross examination, he said the DC had no mandate to hammer mark Mukula logs. He said the DC was blocking the Forestry Department at Mpulungu District. He said the Forest Officer at Mpulungu indicated that he had no authority unless the DC authorized. He added that the DC's actions were at variance with the Forestry Department. He added that the Forestry Department in Mpulungu falls under the DC's office. -J4- I I I I I I I I 3.0 THE DEFENDANT'S CASE 3.1 Mr. Martin Mugala, a Forest Officer based at Mpulungu District testified for the Defendant. In his brief witness statement, he stated that the Plaintiff, whom he inadvertently referred to as the "Defendant" had a valid conveyance licence. He said the Forestry Department never stopped the Plaintiff company from operating, neither did it frustrate the Plaintiff from hammer marking its timber at any point. 3.2 According to him, the Forestry Department had no role to play in the seizure or disruption of the Plaintiffs business and operations. He said the Forestry Department was not aware of the alleged seizure, neither was it aware of persons engaged in the operation to seize the Mukula trees since the seizure was carried out by non-forest officers. 3.3 He said for matters relating to the Forestry Department, the DC could not instruct him: that the DC could only instruct him to attend a meeting. He said he was not aware that the District Joint Operations Committee dealt with Muk:ula trees in 2017. 3.4 In cross-examination, he said it was part of his duties to hammer mark Muk:ula logs. He said he did not hammer mark the Plaintiffs Muk:ula logs in 2017. He said he was aware that the Plaintiff was harvesting Muk:ula trees, but was not aware, if any logs left M pulungu or not. He said there was no reason for the logs not to leave Mpulungu. -JS- 3.5 He said he was not aware of any operation to stop the movement of the Plaintiffs logs. He said his immediate supervisor was the Principal Technician. 3.6 He said he was aware that the Plaintiffs logs were impounded. He said it was alleged that the DC at Mpulungu disrupted the Plaintiffs business. He said the Forestry Department at district level sits under the office of the DC. He added that the DC cannot act under forestry laws because, he was not authorized to do so. He said the DC overstepped his power, but there was no complaint of his overreach. 3.7 He said at the material time, he was alone in Mpulungu District with a driver at the station. He denied being part of the operation that was carried out by the DC against the Plaintiff. 3.8 He said he never received a request to hammer mark the Plaintiffs logs. 4.0 THE PLAINTIFF'S FINAL SUBMISSIONS 4.1 The Plaintiffs Counsel argued that the Plaintiff having fulfilled the requirements of the law by being in possession of the requisite licences, the Plaintiff was entitled to conduct its business without interference. It was submitted that, the Plaintiffs operations were disrupted by the DC for Mpulungu District, alongside other government officials, forest officers and other security personnel who seized Mukula logs, and arrested -J6- the Plaintiffs employees for allegedly being in possession of illegally harvested Mukula logs. 4.2 It was argued that the Defendant's actions constituted a breach of contractual obligations inherent in the licences granted to the Plaintiff. That the wrongful seizure of the logs and the unjust arrest of the Plaintiffs employees constituted a breach of contractual obligations. It was added that the breach on the part of the Defendant prevented the Plaintiff from fulfilling its contractual obligations with its clients. 4.3 It was submitted that contrary to the Defendant's position that it never disrupted the Plaintiffs operations, the Defendant was privy to the disruption caused to the Plaintiffs operations. This was consolidated by reference to a letter dated May 14, 201 7, stating that the Plaintiff informed the Director of Forestry, of the Mpulungu Forestry Office's refusal to hammer mark the Plaintiffs logs. 4.4 It was submitted that there was clear evidence that the Forestry Department at Mpulungu was acting on instructions of the Government of the Republic of Zambia through the office of the DC, as such, the actions of the Defendant constituted a breach of a contractual obligation inherent in the licenses granted to the Plaintiff, to the detriment of the Plaintiff. 4.5 The case of Hadley v Bexendele1 was cited in which it was reported that, the Court held that when a party breaches a contract, the defaulting party is liable for all losses which were -J7- reasonable as a consequence of the breach at the time the contract was executed. 4.6 It was submitted that, the State was responsible for the disruptions occasioned to the Plaintiff, and was liable for its losses. Section 3 of the State Proceedings Act was relied upon, which provides: 4.6.1 3. Subject to the provisions of this Act, the State shall be subject to those liabilities in contract to which, if it were a private person of full age and capacity, it would be subject and any claim arising therefrom may be enforced as of right against the State in accordance with the provisions of this Act. 4.7 It was argued that the Plaintiff was entitled to the claims as pleaded. In addition, it was submitted that the claim for exemplary damages was tenable, in the light of the harm inflicted to the Plaintiffs business, reputation and goodwill. The case of Kapwepwe v Zambia Publishing Company Limited2 was adverted to, wherein the Supreme Court held: 4.7.1 In Zambia exemplary damages may be awarded in any case where the defendant has acted in contumelious disregard of the Plaintiff's rights. 4.8 And citing the case of Attorney General v Martha Mwiinde3, it was argued that the conduct of the Defendant was aggravating; in the sense that, despite knowing that the Plaintiff was not harvesting timber illegally, and even after the acquittal -J8- of its employees, the Defendant repeatedly refused to hammer mark the Plaintiff's logs. 5.0 THE DEFENDANT'S SUBMISSIONS 5.1 In its submission, the Defendant acknowledged that the Plaintiff had at the material time a valid Forest Concession Licence, for the subject area, a valid Production Licence for 101 cubic meters of Mukula trees. And according to the Defendant, the issue was: whether the disruption in operations that the Plaintiff suffered at the hands of the District Commissioner and as a consequence of which the Plaintiff suffered loss and damage would vicariously bind the Defendant. 5.2 It was observed that the administration of forests and botanical reserves was within the mandate of the Forestry Department, and that the DC was neither a forest officer nor the head of the Forestry Department. The operation allegedly carried out by the DC was described as a "frolic of his own". 5.3 Equally, it was acknowledged that actions against the State for tortious acts by its servants or agents are founded on the same common law principles of vicarious liability, but codified by the State Proceedings Act. Section 4 of the Act was cited which provides: 5.3.1 4. (1) Subject to the provisions of this Act, the State shall be subject to all those liabilities in tort to which, if it were a private person of full age and capacity, it would be subject- -J9- (a) (b) (c) in respect of torts committed by its servants or agents; in respect of any breach of those duties which a person owes to his servants or agents at common law by reason of being their employers; and in respect of any breach of the duties attaching at common law to the ownership, occupation, possession or control of property: lie Provided that no proceedings shall against the State by virtue of paragraph (a) in respect of any act or omission of a servant or agent of the State unless the act or omission would apart from the provisions of this Act have given rise to a cause of action in tort against that servant or agent or his estate. 5.4 It was noted that pursuant to section 5 of the Forestry Act No. 4 of 2015, it was the responsibility of the Forestry Department to manage and control national forests , and not the function of the DC to do so. Additionally, it was observed that the head of the Forestry Department at District level was the Forest Officer exercising delegated authority. And that the power to seize timber logs suspected to have been illegally harvested vests in authorized officers; section 74 of the Act was cited. And that by virtue of section 3 of the said Act, an "authorized officer" is defined to mean: a forest officer, a law enforcement officer or an honorary fore st officer. 5.5 Based on the foregoing, it was argued that the State could not be held vicariously liable for the damage or loss suffered by the -JlO- Plaintiff at the hands of the District Commissioner, because he was acting outside the course of his employment. 5.6 In the alternative, it was contended that, even assuming that the individuals that disrupted the Plaintiffs operations were employees of the Forestry Department or law enforcement officers, this assumption alone was incapable of making the State liable, unless it was demonstrated that the officers had no ulterior motive. The case of D. Landless v Attorney General4 was cited, wherein the Supreme Court stated: 5.6.1 It is clear that a wrongful act committed in the course of a servant's employment will only fix the employer with liability if the course of employment has not been broken by some exterior motive. 5.7. It was maintained that, the operation carried out by the DC was a frolic of his own. And I was urged to dismiss the Plaintiffs claims. 6.0 DETERMINATION 6.1 I have carefully considered the evidence adduced and the parties' respective submissions. I am satisfied that the Plaintiff was granted a Concession License (Medium Scale) for purposes of harvesting Mukula timber in the Chinakila Open Forest in Mpulungu District for a period of three years with effect from December 6, 2016. In addition, the Plaintiff was granted a Production Licence (PL No. 305363) to cut and manufacture forest produce, namely Mukula trees, and the quantity was 101 cubic meters at the unit price of K375. And the total paid to the -Jll- government in this regard was K37, 875.000. The licence was valid up to February 16, 2017. 6.2 And having satisfied the requirements of the law, the Plaintiff proceeded to cut Mukula trees and process the same into logs. It is reported that a total of 105. 56 cubic m eters of Mukula logs was harvested. And I find it probable that around March, 2017, the logs were seized in an operation headed by the DC for Mpulungu, by a team otherwise named "Mukula Task Force". And some of the Plaintiffs employees were indicted for illegal processing of Mukula trees. 6.3 The letter by the Plaintiff to the Director of Forestry dated May 14, 2017, substantially demonstrates the Plaintiffs grievances. It was drafted as follows: 6.3.1 Dear Sir/Madam, DENIAL TO HUMMER MARK OUR TIMBER PRODUCTS AND NORMAUSATION OF OUR OPERATIONS We wish to bring to your attention that, the matter in which seven of our people were arrested under the instntction of Mpulungu District Commissioner was disposed off through a no case to answer acquittal. On the 28th April, 2017 we obtained conveyance permit to move twenty cubic meters of logs to Kasama for further processing but the District Commissioner Mpulungu instntcted your DPO Mpulungu not to proceed with hammer marking as there was a written suspension on the -J12- license of production and conveyance permits from your office. tabled before the District The above concerns of Commissioner were the Provincial Officer and Provincial Permanent Secretary in which guidance was given by phone pertaining to the in-house memo from your office on suspension of issuance of production and conveyance permits and that the suspension was lifted, but however the District Commissioner sought a counter memo on the lifting of suspension from your office which he claims he has not received to date and that his efforts to contact you by phone have yielded no response. their operations In view of the said happenings we write to you to seek guidance on the DC's concerns as other districts in the country have normalised except Mpulungu. It is also our view that, failure to normalise our operations in Mpulungu with the DC which seems to be operating at variance with the Forest Department could lead to constructive cancellation of our concession license as most statutory obligation will not be met. Yours Signed Kapilima Mubanga. 6.4 Th e seizure of th e h arvested Mukula logs a t th e hand s of the DC for M pulungu Dis trict and h is team, leading to the paralysis of the Plaintiffs operations a s regard s the processing of 101 cubic m eter s of Mukula trees was illegal. Ther e was no r eas on a ble cause to justify t h e m isfeasance of t h e DC and h is team. The team that carried ou t the operation to paralyze the -J13- Plaintiffs duly authorized business, under the oversight of the DC was carried out under the purported delegated mandate of the government to control, manage, administer forest produce, albeit the execution of the said mandate was improper. 6 .5 The non-participation of the Forestry Department per se in the sting operation to seize the Plaintiffs Mukula logs did not and does not exonerate the State from vicarious liability. The definition of authorized officer, under the Forestry Act, includes a law enforcement officer, conferred with the mandate to inter alia seize any forest produce reasonably suspected to be illegally harvested. 6.6 Noticeably, the seizure of the Mukula logs and the arrest of the Plaintiffs employees under the oversight of the DC was carried out by the Zambia Police. 6.7 And the subsequent nonfeasance (failure to act) by the Forestry Department to lawfully normalize the Plaintiffs operations for the Plaintiff to harness its investment consolidated the misfeasance by the DC, the Police and the team. There can be no evasion of liability by the State under the fa9ade that the actions of the DC were solely a frolic of his own tainted by ulterior motive. 6 .8 The DC even went to the extent of preventing the Plaintiff to have its logs hammer marked by the Forestry Office in Mpulungu, despite the witness for the Defendant acknowledging that it was his duty to hammer mark the logs. -J14- And the logs remained unmarked despite knowing fully well that the Plaintiffs operations in M pulungu District were legal. I take it that the inaction by the Forestry Department, even at the level of the Director, to rectify or react to concerns that affected the Plaintiffs operations, when the Plaintiff was legally conducting its business, amounts to acquiescence to the DC's conduct. 6.9 It is compelling to take notice of a Press Statement issued by the then Minister of Lands and Natural Resources, Hon. Jean Kapata dated June 13, 2017, exhibited by the Plaintiff at pages 58 to 62 of its bundles of documents. The statement was titled: Status of Forest Operations. In that statement the Minister announced a number of measures that had been put in place between February and May 2017, aimed at curbing illegal harvesting, transportation and trading of timber. 6 .10 And some of the measures announced included delegation of some functions on the control of harvesting and trade to the Provincial Ministers to work with the Provincial Joint Operations Committee to curb illegal timber activities. 6.11 Therefore, the argument that the DC was on a frolic of his own is factually and legally unfounded, and not sufficient to exonerate the State from liability. 6.12 I now turn to address the Plaintiffs claims, starting with the claim for the sum of US$ 175,000.00 for prospective loss of income. It was argued that had the Plaintiff been allowed to -J15- proceed with its business venture, the processing of 101 cubic meters of Mukula timber would have yielded the sum of $175, 000.00. 6.13 The question begs, whether the Plaintiffs claim presenting the sum of $175,000.00 in this regard is tenable at law. In considering this issue, I have regard to the English case of Beaudesert Shire Council v Smith5 . The brief facts are that, Mr. Smith owned a farm, and for his water supply for the said farm, he pumped water from a natural water hole in a river. He had a license under the Water Act that permitted him so to do. The Beaudesert Shire Council took 12,000.00 yards of gravel for road construction out of the bed of the river. The act of the Council affected the water hole and altered the flow of the river so that Mr. Smith could no longer pump water from the water hole. And he would have to incur expenses to pump water from another site. He brought an action against the Council for damages. 6 . 14 The Council argued that they were authorized by a permit issued under the Water Act to take the gravel. However, it was held that the Council's actions were not permitted by any provision of the law. Mr. Smith's claim was upheld in the High Court in the sum of£ 5,000. And on appeal, the Court of Appeal in supporting the trial Judge's decision had this to say: 6.14.1 It appears to us, therefore, that if what the appellant did was actionable at the suit of Smith and his personal representatives for -J16- damage suffered thereby, liability must depend upon the broad principle that the Council intentionally did some positive act forbidden by law which inevitably caused damage the continuing exercise of his rights as a licensee for some thirteen years. Such a cause of action must, we think, be found either in, or by analogy with, an action on the case for trespass. to Smith by preventing 6.15 The Court further stated: 6.15.1 Bearing this in mind, it appears that the authorities cited do Justify a proposition that independently of trespass, negligence or nuisance but an action for damage upon the case, a person who suffers harm or loss as inevitable consequences of the unlawful intentional and positive acts of another is entitled to recover damages from the other. It may be that a wider proposition could be justified, but the proposition we have stated covers this case and leads us to the conclusion that the appellant is liable to the respondents for loss occasioned by its unlawful trespass in removing gravel from the river-bed. 6.16 The above stated approach and principle was adopted in another Commonwealth jurisdiction, namely, Australia, in the case of Northern Territory of Australia and Others v Mengel6 . In that case, public officers were held liable for economic loss occasioned to the plaintiff. The facts of the case were that, in 1988 a campaign was carried out throughout Australia, by the Commonwealth and Territory Governments to eliminate tuberculosis and brucelios in cattle and buffalo. In -J17- the Northern territory stock inspectors, believing they were justified in doing so, directed the plaintiffs who owned two cattle stations that they could not move breeding cattle and that they were under quarantine. For more than two months the plaintiffs did what they were told and did not move cattle, as such they did not sale a large number of cattle as planned. 6.17 The inspectors then notified the plaintiffs that the quarantine was lifted. Believing they suffered loss as a result of interruption to their business, the plaintiffs claimed reimbursement from the government and the inspectors for their losses. In the High Court, the inspectors' actions were declared unlawful and the plaintiffs were awarded damages for loss in consequence in the sum of $400,537, but the claim for negligence and other claims were dismissed. 6.18 On appeal the Court of Appeal upheld the High Court decision and policy consideration at pages 106 and 107 of the judgment as to who should be held liable to pay the damages, Priestley J., inter alia stated: 6.18.1 The difference between private persons and governmental and other public body defendants, so far as the availability against them of the Beaudesert action on the case is concerned, is illustrated by the facts of the present case. BTEC was being administered by the defendants pursuant to governmental decision, the government's function and duty being to administer the laws of the Territory for its peace.... The invalid but bona fide actions of the -J18- defendants were done in the course of their employment duties which were necessarily directed to this general public benefit. The damage caused on private persons in this case by the defendants' actions as public persons in this case must be borne either by the private persons, who themselves did nothing to bring about their loss, or the government whose officials caused the loss in their mistaken efforts to pursue what must be taken to have been a desirable public objective. To me it seems clearly appropriate that in such circumstances public funds should meet the losses, rather than those private persons not at fault. 6.19 It is my resolve that the Plaintiff in the present case is entitled to recover the loss of prospective income, subject to assessment of damages. In other words, the claim of $175, 000 is subject to assessment of damages. 6.20 Having allowed the claim for loss of prospective income, and having regard to the fact that the claims in the sum of K37, 875.00 and K250,000.00 cover expenses leading to the recovery of prospective loss of income, which encompass the expenses therein, the two claims cannot be awarded separately or together with the loss of prospective income. Ordinarily, the claims for loss of K37, 875.00 and K250,000.00 would have been awarded, if the Plaintiffs action ended at claiming only a refund of expenses incurred, without a claim for prospective loss of income. -J19- 6 .2 1 Turning to the claim for general and exemplary d amages. Considering the con du ct of the Defend ant 's agents or employees to unlawfully interfere with th e bu siness operation s of the Plain tiff, d espite several a pproach es, and wh en no law allowed him so to do, is cen surable. To th is exten t, damages for exemp lary damages are tenable. In the case of AB and Other v South West Water Services LtcP Lord Devlin h a d this to say regarding th e h ead of exemplary damages: 6.2 1.1 or action, Exemplary damages were limited not by the cause of action sued on but by the status of the defendant and the quality of his conduct. Accordingly, if the conduct complained of by the plaintiff consisted of a deliberate, calculated and willful attack upon his rights by a defendant whose status fell within the category of a government servant engaging in oppressive, arbitrary or unconstitutional whose motivation was calculated by him to make a profit for himself which might well exceed the compensation payable to the plaintiff, then the defendant could be liable for exemplary damages regardless of the cause of action sued upon. Thus, exemplary damages could be awarded in a claim of public nuisance against a public authority where the conduct complained of consisted of a deliberate, calculated and willful interference with a person's rights as a member of the public in circumstances which were oppressive, arbitrary or unconstitutional or where the authority intended to make a profit greater than the compensation which would otherwise be payable to the plaintiff. -J20- 6.22 And our own Supreme Court, in the case of Martin Nyandoro v Attorney General8 (head-notes): 6.22.1 In awarding exemplary or aggravated damages the conduct of the parties has always been taken into account. It would be difficult for the court to award damages where evidence has not been led to prove the conduct of the parties where torture and brutality are alleged. 6.23 Therefore, the award of exemplary damages in the present case is appropriate as the way of denouncing the conduct of the said DC and other State actors, as agents of the Defendant. 7.0 CONCLUSION 7 .1 In the light of the foregoing, the Plaintiffs claim for loss of prospective income succeeds subject to assessment of damages by the Registrar of the High Court. And if damages thereof are proved, the award would in principle restore the Plaintiff to the position it would have been had the State not interfered with its operations in an unlawful manner. Consequently, the claims for the sums of K37,875.00 and K250, 000.00 fall out for duplicity. 7 .2 And in relation to exemplary damages, the amount I generally find to be a fair solatium is the sum of K40,000.00. 7.3 The aggregate of the sums found due shall carry interest at the average short deposit rate from the date of writ to date of -J21- judgment and thereafter at the rate of 6% annum until final payment. DATED THIS 318 T DAY OF DECEMBER, 2025 ..............................•................................. THE HON. MR. JUSTICE CHARLES ZULU -J22-