BP Southern Africa (Pty) Ltd, a licensed fuel warehouse operator and exporter, claimed refunds of duty-at-source (DAS) paid on fuel allegedly exported to Zimbabwe. SARS investigated and concluded that the fuel had not been exported but consumed locally, relying on evidence including lack of export from licensed warehouses, non-existent or improper consignees, falsified documentation, and transporters not licensed as removers of goods in bond. SARS issued letters of demand in February 2020 and, after non-payment, filed a certified statement under s 114(1)(a)(ii) of the Customs and Excise Act on 16 March 2020, which had the effect of a civil judgment, and attempted execution. BP launched urgent applications seeking interim interdicts to restrain execution pending review proceedings, truncation of the s 96 notice period, and later sought to file a supplementary founding affidavit in review proceedings. The High Court dismissed the interim interdict applications and refused admission of the supplementary affidavit. The full court dismissed BP’s appeals, and BP sought special leave to appeal to the Supreme Court of Appeal.