Nelson Mandela's burial site forms the core of the Mandela versus Mandela battle, currently playing out in the Eastern Cape High Court in Mthatha.
The contents of the affidavit filed by Makaziwe Mandela and 15 others, including Graça Machel, reveal that this faction of the family believes Mandla Mandela wants to "force" Nelson Mandela's place of burial away from Qunu, to Mvezo, for financial gain.
On Wednesday, Judge Lusindiso Pakade ruled that the graves of the three Mandela family members had to be moved back to Qunu by 3pm on Wednesday. But Mandla Mandela hit back with an application for that order to be rescinded.
Mandla Mandela, in response to Makaziwe's initial application, told the court that Makaziwe's argument – that Nelson Mandela wished to be buried with his three deceased children – held no water in customary law.
He said that the "tenuous" links Makaziwe had made to his grandfather were not properly justified.
But in Makaziwe's affidavit, she accuses Mandla of an "agenda to confound the last wishes of Nelson Mandela".
"There is a reason, of national interest, to redress the unlawful actions with haste," Makaziwe and others say.
"The applicants, as custodians of the last will and testament of Nelson Mandela will have duties to ensure his last wishes are carried out in the event of his demise.
"The actions of Mandla Mandela in unlawfully violating the graves of the three deceased would appear to be in furtherance of an agenda to confound the last wishes of Nelson Mandela."
Buried in Qunu
They also submitted that Nelson Mandela has asked to be buried in Qunu, and that Mandla Mandela was therefore trying to "force" his burial to take place at Mvezo by moving his children's graves.
"It is conceivable that such a heritage site has the potential to generate monetary gain. Indeed, there is evidence to suggest that the first respondent has already begun preparations at the Great Place in Mvezo, inclusive of construction buildings," the applicants said.
The exhumation was to take place at 3pm on Wednesday.
The original court order was made last week after 16 members of the Mandela family, including Mandela's oldest daughter Makaziwe Mandela, requested an urgent interdict against Mandla. Those proceedings were held in chambers.
Makaziwe Mandela, her nephew Ndaba Mandela and niece Ndileka Mandela were in court to observe proceedings on Wednesday.
The graves are those of Mandela's eldest son and Mandla Mandela's father, Makgatho Mandela, who died in 2005; Mandela's first daughter Makaziwe Mandela, who died as an infant in 1948; and Mandela's second son Madiba Thembekile, who died in a car accident in 1969.
Order was granted 'erroneously'
Both Mandla Mandela and the other faction of the family were asked to file papers by 10am on Wednesday. But Mandla asked the court to overturn the initial order on the basis that he did not receive a summons to appear in court on Friday, and could therefore not adequately defend himself.
His lawyers argued that the order was granted "erroneously".
During proceedings, lawyers for Makaziwe accused Mandla of moving the bodies "illegally, in the dead of night".
It was reported on Tuesday that charges were laid against Mandla for the alleged illegal exhumation.
But advocate Phillip Zilwa, for Mandla Mandela, argued that the case brought by Makaziwe and 15 others was "frivolous", and that his client was unnecessarily dragged to court.
Advocate David Smith, for the Makaziwe faction of the Mandela family, argued that Mandla's application (to have Friday's order rescinded) did not deal with the substance of the application, which is how the graves were moved.
Smith charged that Mandla's actions were "legally indefensible". – Additional reporting by Sapa