MR BERGER
Mr Lax and the Committee, 19.3 (a) 2 is not properly construed the Committee's request for further particulars.  The Committee's request for further particulars is indeed in terms of Section 19 (i) and I'll explain why.  My learned friend, Mr Brink, with respect is not correct because 19.2 says once you've got the application then the Committee can make certain enquiries then 3 says "After such an investigation, the Committee may inform the applicant that the application judged on the particulars or further particulars contained in the applications, or provided by the applicant or revealed as a result of enquiries made by the Committee, if any, does not relate to an Act associated with a political objective.  So the Committee then writes back to the applicant and says "Your application, together with the further particulars which you have supplied to us, does not reveal an act associated with a political objective."  Then the applicant is afforded a further opportunity to make a further submission as to why the act should be regarded as an act associated with a political objective and then, and 3 - then the Committee decides whether the application, judged on the particulars referred to in sub-paragraph 1, that's the application plus the further particulars, and in such further submission relates to an act associated with a political objective and if it is satisfied that the application does not relate to such an act in the absence of the applicant and without holding a hearing refused the application and informed the applicant accordingly.  So it's, with respect not, not the further particulars, it's the Committee forming a view which was not done in this case as far as I know, that the applications as submitted do not disclose acts associated with a political objective and then say "you've now got one further opportunity to convince us that it is an act associated with a political objective" and that's why it's so important that the original application be under oath and be substantially complete to the extent that the applicant must say "these are the acts for which I seek amnesty - this is what I did" and the applicants don't do that and they definitely don't do it under oath, all they do is give a case number.  If one managed to relate that back to the Boipatong criminal trial because no court was given at that state, but even if one says alright they were referring to the Boipatong trial, they are asked in that document "which charges were you convicted of?" - "details to follow" and if one reads the 3000 pages of the Boipatong record, there's a complete denial.  So, at this stage, one doesn't know what act the applicants are applying for amnesty for.  Beyond that, one doesn't know what the political objective is because if one reads the Boipatong criminal trial there is no mention at all because of the denial, there is no mention of a political objective.  So the very basic fundamentals of an Amnesty Application are missing and that's why we submit that there hasn't been any compliance, not even substantial compliance and we set out in paragraphs 13.1 through to 13.6 what we submit are the fundamental particulars which ought to be in an amnesty application.  It's correct that, that then shuts the door on the applicants but this is a situation entirely of the applicants own making.  If you will just bear with me for a moment.
	Chairperson and Members of the Committee, I have tried to deal with as many points as possible which might come up in the argument of my learned friend but at this point I'll rest and save the rest for reply.