Illegal mining activities have assumed serious proportions, with about 6 000 people estimated to be involved in illegal underground mining and another 8 000 in illegal surface mining. In 2011 alone, it was estimated that illegal mining subtracted about R6-billion from the country's fiscus. Free State Supreme Court Judge Jake Moloi stated that "these illegal activities are orchestrated and are syndicated with the foot soldiers doing the dirty work for the faceless bosses". In many cases illegal miners have died - either because of accidents underground or because of fights between rival gangs underground or through the actions of mine security. Illegal mining and also the theft or destruction of mining assets have been a feature of the poorly managed liquidations of mines such as Pamodzi Gold and Blyvooruitzicht. Illegal mining activities have jeopardised or prevented the re-opening of such mines, with further negative implications for mining employment. Illegal mining is also associated with increased environmental harm.