The manager of a Cape Town orphanage, who is facing fraud and corruption charges, is far from a flight risk as she has built a life in South Africa, the Cape Town Magistrate's Court heard on Monday.
The 49-year-old Cameroonian national's lawyer, Andre Johnston, said the State had alluded to various sources saying she would flee at the first opportunity, but had never laid out details in court.
"With no disrespect, it's a futile attempt ... it was my view that it was not credible," he added.
"How many South Africans ... by birth ... can say that they own a property? Or have a daughter who is attending medical school?"
Johnston said the court should consider that everyone sitting in the public gallery were there to support the accused.
Magistrate Reaz Khan said the accused had wanted to be released on bail so she could keep running the orphanage, but it was already closed down.
Johnston said his client still planned to fight the City of Cape Town on the closure.
The accused, who ran the Al-Noor Child and Youth Care Centre, faces a charge of conspiracy to commit fraud and three of contravening the Immigration Act.
The social development department removed 17 children from the facility on the back of allegations of physical and sexual abuse. It co-ordinated efforts to reunite the children with their "immediate family" after the centre was shut down.
The accused is not being named as she faces potential sexual offence charges. Other charges are expected to be added soon.
In an affidavit, she shared the effect that incarceration was having on her two daughters (aged five and 19), her poor health and her financial commitments of around R11 000 a month.
She also said she intended pleading not guilty as she believed she had not committed any offences.
The investigating officer had previously stated the reasons he thought it was too risky for her to be released on bail.
In an affidavit read out by the State on Monday, Home Affairs official Adrian Jackson explained how he had uncovered her various alleged violations of the Immigration Act.
He alleged that she had obtained citizenship under false pretences, used different aliases, and had even approached two vagrants to pose as partners in a marriage scheme.
The court previously heard she had allegedly bragged about buying her citizenship and that it was in the process of being reviewed and withdrawn.
Johnston said citizenship could not be arbitrarily withdrawn.
He said bail should be set with conditions and that he would be happy to hand in her South African passport, the only one that appeared to be valid.
The case was postponed until Wednesday for the State's bail arguments.