MR LANDMAN
Thank you Mr Chairman.  Mr Chairman before I proceed with the (indistinct) written Heads of Argument which were supplied to the Committee, I understand, a few minutes ago.  Mr Chairman may I deal with one matter, it arises from certain press reports which have appeared in the last two days and they concern the implicated person on whose behalf I appear, General Nyanda.  The press reports are to the effect that General Nyanda did not submit an application for amnesty to the Truth Commission.  I'm instructed and indeed I've had sight of his applications, in fact there are two applications by him and therefore there is an application or two applications by him before the Truth Commission.  A date has not yet been set for the hearing of those applications, but nevertheless I just want to dispel the notion that he has not applied for amnesty.  	Mr Chairman I then would seek leave to take the Committee briefly through the Heads of Argument.  Mr Chairman you will note that there are certain references to the ANC's submissions.  I have in the short time been able to obtain a copy of the official submissions, with the official page numberings and I have been able to find a number of those statements and the page numbers.  Those that I haven't found I will find as soon as possible and convey it to the Committee.
	Mr Chairman it's our submission that the factual context within which the operation occurred is essentially not an issue.  Mr Chairman on page 2 of the Heads of Argument, paragraph 2.4, we refer to a pamphlet which was published after discussion at the COBWE Conference, encourage cadres of MK to take the struggle to the White area.  Mr Chairman that is dealt with at page 52 of the first submission and Mr Chairman we then place the encouragement given to the cadres in that pamphlet in it's context as testified to by the second applicant in this matter.  
	Mr Chairman it's been pointed out to me by my instructing attorney that there may be a possible misunderstanding.  I am not suggesting in the Heads of Argument that it was only after the COBWE Conference in 1985 that members of the Security Forces were considered to be legitimate targets.  It was more a case of after that conference there was an intensification of the armed struggle and certainly there was also a view that the struggle should be taken into the White areas.  
	Mr Chairman at all stages throughout the struggle from the 1960s Security Forces were considered to be legitimate targets in terms of ANC policy.  Mr Chairman on page 3, paragraph 2.8, at the bottom of the page, we make the point that the attacks in the White areas were not to be random and indiscriminate.  The policy was clear that the targets were the racist army, police, death squads, agents and stooges and the call to take the war to the White areas is defined as inter alia systematic attacks against the army and police.  	Mr Chairman that appears not only in the second submission but also in the first submission at page 52.  Mr Chairman the context within which this attack took place was that it was an attack that was planned and co-ordinated from the Swaziland Regional Politico-Military Committee which at the time was headed by General Sepiwe Nyanda.