UNKNOWN
Honourable Chairperson, there was never any 
declaration of war, but a war did exist.  With respect, if one 
compares this to the period when the ANC and the SACP waged 
their war, there was no expressed declaration of war, but there 
was a struggle and a fight, and a struggle consists of two sides, 
one shoot the other, one plant bombs towards the other, one kill 
the other, but there was killing on both sides, but the perception 
existed that a war existed and furthermore tat during this time, 
there was a particular war.
	And that is what the witnesses said yesterday, they were 
called here independently and the testified that they perceived it 
as a war.  In those circumstances it was regarded as a war, and 
the circumstances which had to be prevented would be the 
takeover of the ANC and SACP while the National Party had lost 
its course.
	That is what they were prepared to do in order to prevent 
this.  That is the objective that the applicant held.
	Honourable Chairperson, as I have already stated, the 
target which was set, was Mr Chris Hani to bring that particular 
party to its knees, to take out the leadership so to speak, and 
then further problems or to combat further problems that existed.
	I would like to argue with respect that the applicant, as we 
have already referred to in our heads, falls within the category of 
Section 20(2)(a) and (2)(d).  With reference to the criteria, I 
have ...