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Their is a gap in the act but it is suggested that rather have a License. The insurance companies does not cover any person who does not have the necessary permit.
We operate in a rural part of Limpopo province- most of our workforce are illeterate and cannot (legally) manage to get a license. WE make extensive use of agricultural tractors that these folk are quite capable of operating. There is no need for them to go on public roads. I will need to check with our insurers what their stance would be in cases such as this
I understand the predicament, If insurers allows it I can not see why you do not need them to have a license