This is the submission of ANC chief whip Mathole Motshekga to the Constitutional Court in an answering affidavit to an urgent application brought by DA parliamentary leader Lindiwe Mazibuko. She has asked the court to overturn a ruling by Western Cape High Court Judge Dennis Davis and allow for the motion of no confidence to be debated no later than December 7.

Motshekga, who is cited as the second respondent in the application, notes that parliament is already in recess and that some of its 400 members will be on oversight duty around the country, or on study tours abroad, during the period in which Mazibuko demands a special sitting be held.

"Members of the National Assembly will have to be flown to Cape Town from the rest of the country and the world," Motshekga said.

"It is estimated that a special sitting of parliament, if convened by the presiding officer, will incur a cost of R12-million."

But Mazibuko dismisses this argument in her application to the Constitutional Court, arguing that a motion of no confidence in the president is of such national importance that it must take precedence over all the other business of the National Assembly.

"It is axiomatic that administrative inconvenience can never be a reason to postpone or frustrate the realisation or protection of a right, let alone an important one like that at issue in this case," says Mazibuko.

Motshekga repeated his accusation that the DA and the other opposition parties sponsoring the motion are pushing for an urgent debate because they want to influence the outcome of the ANC elective conference next month.

He said Mazibuko indicated her opposition to Zuma's re-election when she asked him, during a debate on the budget of The Presidency, not to contest for the presidency of the ANC.

"What the applicant seeks to do is to force by stealth a confidence debate in the president so as to affect his chances of re-election as president of the ANC and the country for another four-[sic] year term," said Motshekga.

Dismissing Mazibuko's application - on behalf of the eight opposition parties that back the motion - Judge Davis warned that the courts were increasingly being politicised. He agreed that the motion of no confidence should be debated urgently but said he could not prescribe to parliament.

National Assembly speaker Max Sisulu described Mazibuko in his answering affidavit as the "author of her own urgency" .