Former workers at Ahlan Wa Sahlan, a concrete block factory in Philippi, have painted a picture of an uncaring employer who made them work long hours for low pay in difficult conditions.
Representatives of the factory declined to speak to the Cape Argus.
The workers also claimed safety was an issue at the factory, and that their situation was "unbearable".
In an affidavit, Charlton Bosman of Carnarvon said: "I was employed... for six months last year, up until December 17. I have already tried to recover the outstanding monies from Mr Faizal (owner) without any success. Attempts were made by the (Carnarvon) advice office co-ordinator so that we could be paid.
"The owner stated that we must come fetch the money ourselves from Philippi (Cape Town). The problem is that we live more than 600km from the Cape, so we had problems with transport."
Jacques Manuel, 19, said: "I have been in the employ of Mr Faizal at Philippi in Cape Town since August 2004. I terminated my employment at the end of February 2005.
"It was difficult for us to understand the work in the beginning. We were thus under enormous pressure from his foreman to produce. His foreman physically fought with us. This led to us wanting to come home. We, therefore, at the end of February, received money from our parents (in Carnarvon) to return home."
He said they had been paid R50 a day, and had been encouraged to buy food on credit from the shop on the owner's farm. This and a compulsory savings scheme meant they received little money at the end of the month.
"When we left, he still owed us our week's wages and the savings money that was deducted over the seven-month period. We have till date hereof received nothing in this regard."
Manuel also said the workers had been told that if they wanted their outstanding money they would have to collect it in person.
Roland Christopher Andreas, 36, said he had started work at the brick factory on September 20 last year.
"From the beginning we realised that things were not in place... There was no house for us to stay in, we had to empty a container so we could sleep in it. Insofar as drinking water was concerned, there was none. We had to fetch water at Total Garage. There was a borehole, but the water was not filtered. There was also no sanitation system. We discovered that workers had no say."
He also claimed that one of the bosses would "spray you with a can of Doom if you stank and had fleas".
"We never received payslips. Overtime was not accounted for correctly. You sign for your money and get paid out of hand."
Andreas said a worker had been stabbed and bosses had refused to call an ambulance.
"When your people called you, they were told that you were not available. You were therefore cut off from the rest of the world."