ADV TEE
Mr Chair and members of the Committee, then I am going to move to the argument concerning the full disclosure of the relevant facts.  I would submit that the proper way of interpreting that aspect is that the full disclosure of all relevant facts relates to the question of what is relevant.  A full disclosure of what is relevant is not the same as a full disclosure and the reason is that lawyers have long known that there is a difference between evidence which is admissible by virtue of relevance and evidence which becomes inadmissible by virtue of irrelevance or hearsay.  Now, if one takes that as the bench mark of what needs to be stated, the relevant facts here relate to the question of what actually took place and I would submit that their are four key relevant facts.
	The first one is the fact of the order and that is divided into two parts.  The general order and the specific order relating to Shabangu.  The second one relates to the fact of the chain of command.  The third one relates to the fact of the attack and the fourth one relates to the fact of their motives, because that necessarily then brings into play Section 20, sub-section 3 of the Act where they justify.  Now, for example, where the Commission is faced now with a conflict of versions relating to the individual facts, because one party says two people threw grenades and another party says one person threw a grenade, is that a relevant factual dispute and my submission is clearly it is not, because both are common cause in the following aspect.  The attack took place, we were all party to it.  So there...