UNKNOWN
Mr Chairman, I submit that the applicants have made out a case.  As far as I understand, they have to show that their actions were politically motivated firstly.
	I submit that it is not disputed that they were ANC members, UDF members initially.  It is also not disputed that during the course of their membership as UDF members, they were recruited to become the members of the SDU's.
	I do concede that their recruitment might have been done in an amateurish manner, but nevertheless, I respectfully submit that they were members of the Self Defence Unit.
	The story that Mr Mkhize was participating with the kwaZulu police cannot be regarded as being improbable.  I respectfully submit that the TRC hearings are full of that history of the kwaZulu police collaborating with Inkatha and I respectfully submit that what the applicants have said, should be taken as the truth.
	Regarding disclosure, I submit that in so far as relevant facts are concerned, they have fully disclosed their activities in the killing of the deceased.  They have done so in great detail.  Although I concede that there is an aspect by the last applicant, Mr Mbutho which seems to be unsatisfactorily, that he didn't indicate who the people he got the ammunition from, were.
	But I submit that compared to the overall picture of what he has given to the members of the Committee, he has made a full disclosure and his failure to give the names of the people that gave him firearms, could be attributed to a lapse of memory.
	This incident happened in 1992 and this man has been in jail, he has been thinking about some other things and I respectfully urge that his lapse on that score, should not be held against him.
	The evidence has been led and the members of the Committee are apprised of the evidence, and I respectfully submit that to run through all the evidence would be a waste of time, unless there are specific questions which the Committee wishes me to respond to, I cannot take my argument further than this, thank you.