MR WILLS
There are a number of occasions where they indicate that they were of the belief that the deceased and his gangs were being utilised by the police in the struggle or the counter-revolution against the ANC.  There was a specifically - a specific point on page 6 of the record of this matter where Mr Ndaba and I quote, it says at the bottom of the page
"At the time it was common knowledge that the police were collaborating in harassing the ANC.  There had been many instances where people, that is ANC people had been killed, shot at.  At one time a house attack, that is the Midlands Chairperson, Mr Harry Gwala, which had been attacked by these gang members"
and this is the important sentence, it's the last sentence on that page:
"We then felt that these gang members were being used by the police as part of their counter-revolutionary strategy"
Now that's the closest we can get to that length and I submit that there's nothing to gainsay that bona fide belief and to that extent I submit that they satisfy that requirement.
	Turning to the remainder of my argument on political motivation, purely they were trained ANC security persons, clearly complaints were received about the activities of this gang and I think the context is important in that the complaints were contextualised in such a manner that the activities of the gang were adversely affecting the ability of the ANC to organising that community.  Committee members became scared and in fact Committee members were targeted by this gang.  So it's a political problem, it's a problem that the ANC, if they want to organise, have to sort out.  They then were tasked by a senior person, Intelas Skosana, to investigate.  They investigated and they reported back to Intelas Skosana, their superior, the results of their investigations and he said do something about it.  They then took it upon themselves to do something about it and they took the decision to kill the person.  Now clearly the inference is unavoidable that the motivation in killing this person was to prevent the obstacle to the ability of the ANC to organise in that area, that is why this person was killed.
	They then reported back to Skosana who basically tacitly approved of their activities.  Clearly had they done something that was out of ANC policy as my learned colleague, Mr Mapoma, inferred in his questioning, then surely Skosana would have taken the issue up and possibly the two applicants would have been disciplined but instead, the evidence before the Committee is that when they reported back to Skosana, Skosana was perfectly happy with what they had done.
	There was no ill will or personal gain, no malice in the activities and as regards the proportionality aspect, they didn't attack the gang at large, they took a decision, a minimal approach in fact, to target who they perceived as a gang leader and they killed him and nobody else and the objective was achieved and they did nothing further.  I submit that on this basis their political motivation cannot be doubted, it must be accepted, there's nothing to gainsay any of the evidence.  I understand that there was an unfortunate incident, the demise of the deceased's mother but be that as it may there's no evidence, there seems to be no interest to put any counter version before the Committee and I submit on that basis that it must be accepted particularly in view of the fact that it is the applicants who have brought this to the attention of the Committee and the world at large and nobody else.  Thank you Chairperson.