Founding member and president of the Pan Africanist Congress, Robert Mangaliso Sobukwe, was sentenced to three years' imprisonment for incitement of Blacks to urge the repeal of pass laws. Sobukwe led a peaceful Black march to Orlando police station in Soweto on 21 March 1960, the same day a similar protest took place in Sharpeville, to hand over their passes to police officers, thereby deliberately courting arrest. Sobukwe was arrested and sentenced, but refused to appeal against his sentence, as he had refused the aid of an attorney, on the grounds that the court had no jurisdiction over him because it could not be considered either a court of law or a court of justice. After his prison term had expired, the new General Law Amendment Act (no. 37 of 1963) was passed to allow his imprisonment to be renewed annually at the sole discretion of the Minister of Justice. This procedure became known as the "Sobukwe clause" and went on for a further three years. He was the only one imprisoned under this clause. In 1969 he was put under house arrest in his home in Galeshewe, Kimberley, until his death.
