Last year, Nhleko found that features at the home such as a kraal, amphitheatre and a pool were actually necessary to protect Zuma, and were thus classed as security features.
Earlier this week, Zuma proposed to the Constitutional Court that the Auditor General and finance minister determine how much he should pay back.
Nhleko appeared to become almost a laughing stock last year after he made findings that certain aspects of Nkandla were security features.