The ECDC loaned money to Bushman Sands Developments (Pty) Ltd, which was secured by a suretyship from No 1 Watt Street (Pty) Ltd (the company in liquidation). When Bushman Sands was unable to repay the loan amount of R19,357,645, ECDC instituted action in the Eastern Cape Local Division, Port Elizabeth, against both Bushman Sands and the company in liquidation. Shortly before trial, Mantis Investment Holdings, as the sole shareholder of the company in liquidation, successfully applied for its liquidation. After the second meeting of creditors at which ECDC's claim was admitted, Mantis' attorney wrote to the liquidators requesting that certain persons and documents be subpoenaed. One of the joint liquidators forwarded this request to the Master, who summoned a number of current and former employees of ECDC to appear before him. ECDC then applied to the high court to review and set aside the subpoenas issued by the Master.