QUESTION A group of people who are informally known as Operation Expulsion have a WhatsApp group comprising of 500 people. The WhatsApp group description reads: "This group is for people who are committed to seeing South Africans being put first". Anyone can join this group by following the WhatsApp link provided on their social network pages. Only administrators of the group can send messages. A week ago, the known leader of Operation Expulsion sent the following on the group: 0. 00 08:30am olle Zandile Fooley Fellow lawful South Africans with Green IDs! We must put South African school children first. At the moment, some schools have turned away SA kids to accept foreigners. SA kids are forced to stay home where they do drugs and become criminals. Our country is falling apart. We can't sit back and do nothing. Operation Expulsion's strategic wing has taken the executive decision that, from next Monday, we will ensure that problematic elements in our schools will be removed with immediate effect. No retreat. No surrender. Please join our infantry! If parents can't find their little illegal golden eagles on Monday after school, that loss lies on their shoulders. Don't come crying to us. Cde Zandile Fooley 08:32 am Anesu Ncube, a journalist, joined the WhatsApp group to track the activities of Operation Expulsion. She is currently a permanent resident in South Africa. She took this upsetting screenshot to the local police station. They said they could do nothing about the matter. She then reached out to the Wits Law Clinic for assistance. The Law Clinic believes that this matter has serious human rights implications because of the e of xenophobia in South Africa (see the UN Report provided here: https:/ews.un.org/en/story/2022/07/1122612). You are a lawyer who wants to see human rights flourish in South Africa, for all people. As such, you believe that the law can be used in strategic ways to combat xenophobia. Prof Minerva McGonagall from the Wits Law Clinic has asked you to draft a legal memorandum on whether the WhatsApp screenshot above constitutes "hate speech" for purposes of the Promotion of Equality and Prevention of Unfair Discrimination Act 4 of 2000 (PEPUDA), and what the appropriate remedy/remedies might be