Study the case of Economic Freedom Fighters and others v Manuel 2021 (3) SA 425 (SCA) and answer the question below. In para [92], the court exclaimed [sic], "An unliquidated claim for damages must be pursued by institution of an action." However, contrary to this accepted practice, the attorneys for the respondent brought the claim of damages for defamation in an application proceeding. Discuss fully, the reasons the court put forward in support of accepted practice, that general damages for defamation must be instituted in an action proceeding. Refer to relevant case law and legislation in your answer.