The commission says Zuma has to obey a court subpoena despite the Constitutional Court reserving judgment on the commission's bid to force him to appear.

In December, Zuma left the commission during a lunch break after refusing to answer questions.

A constitutional law expert said Zuma could be playing for time. The commission is due to conclude on 31 March.

Advocate Michael Osborne said, "the consequences for the inquiry are fairly dire in the sense that the commission's term ends on 31 March. It seems unlikely then that Mr Zuma will ever appear simply because the clock is ticking."

"The council for the commission has made the point that this precisely is Mr Zuma's intent: to use delaying tactics as much as possible in the hope that before a legal decision can be reached. It will be too late in the sense that the commission closes up shop, as it were, on the 31st of March."

eNCA