Menzi Simelane's CV ? President Jacob Zuma's only point of reference in appointing him as National Director of Public Prosecutions ? was "shoddy" and revealed his "inexperience", the Democratic Alliance said on Tuesday.

"The slipshod way in which Mr Simelane prepared his CV reflects negatively on his conscientiousness," said DA chairperson James Selfe in a replying affidavit to President Jacob's Zuma's submission on his appointment of Simelane to head the National Prosecuting Authority (NPA).

"More disturbingly, the lack of care which he devoted to the task justifies... the inference that Mr Simelane knew that his CV was unimportant because the president had already decided to appoint him."

He said Zuma failed to make "appropriate enquiries and investigations" into Simelane's past performance. He did not request performance reports from his former employees.

"... I submit that the failure to make them and to receive and consider reports meant that the president was not in the position to make a proper judgement as to whether Mr Simelane was a fit and proper person as required by section nine of the NPA Act.

"I contend further that the president's failure to make these enquiries also supports the DA's contention that the president not only acted irrationally but also is reasonably suspected of bias."

Selfe said that had Zuma enquired about Simelane's previous performance, he would have discovered that the justice department received a qualified audit from the Auditor General in each of the four year's he was the NDPP's director general and accounting officer.

The president's lawyers had to file the documents Zuma considered in appointing Simelane.

The only candidate considered?

According to Selfe, the only document Zuma referred to was Simelane's CV ? which he submitted was not enough to warrant the appointment to the key post.

"The first point I make in this regard is that the president did not have before him the CVs of any other possible candidates.

"I thus infer that Mr Simelane was the only person the president considered," he said, adding that to appoint a candidate in line with the constitutional requirements, he should have considered a group of possible candidates.

Selfe submitted that Simelane's CV was a "hopelessly insufficient basis" for taking the decision to appoint him.

The CV also showed that Simelane was "very young and inexperienced" to hold his current position, the affidavit read.

"Another thing the president would have learned from Mr Simelane's CV was that Mr Simelane was shoddy in the way he prepared documents," Selfe added.

'Littered with spelling errors'

"A candidate who presents a CV littered with spelling and grammatical errors would in the ordinary course receive short shrift from a prospective employer."

Selfe listed the spelling and grammatical errors. Simelane had misspelt the word "curriculum", his identity number was presented with 12 digits instead of 13, he misspelt "qualification" and "pupillage". Selfe said there were at least nine errors on page five of the CV.

The Ginwala Commission of Enquiry report was not shown as having been consulted, Selfe said.

The commission was established to determine former NPA boss Vusi Pikoli's fitness to hold office.

Ginwala's report was critical of Simelane, finding his conduct as the then-justice department director general was "irregular" and his testimony was "contradictory and without basis in fact or in law".