MR WESSELS
...(sound cut off) and in administrative law jargon, it would have been that a Tribunal had regard to irrelevant facts, which shouldn't have been, it would be a misdirection in terms of law.  I deal with that aspect on paragraph 34 of my Heads, Mr Chairman.
	Then Mr Chairman, there's been many suggestions during the course of these lengthy proceedings, from counsel to the witnesses, which is my submission never went beyond speculation.  And if there is to be a finding that there wasn't full disclosure, it can only be made on inferences that is to be drawn.  And the submission will be that there wasn't a full disclosure of the bomb aspect.  There was no suggestion, as far as I can make out, that there wasn't a full disclosure pertaining to the facts as they related to the Omar and Evans conspiracy to murder itself, the only suggestion is that insofar as the bomb is concerned there wasn't full disclosure on the facts, because there was an attempt in fact, to kill the people and not only to damage the building. 
	Now to come to that conclusion you would have to make inferences from the facts that are proved, or let me not use approved in that sense, but the facts that you find pertain to the incidents.  And then Mr Chairman, it is my submission that you have to, at the very least, apply the test as set out in R vs Blom, and that test is the following:
(1)	"That the inference sought to be drawn must be consistent with all the proved facts.  If it is not, then the inference cannot be drawn.
	(2)	The proved facts should be such that they exclude every reasonable inference from them, save the one to be drawn.  If they do not exclude other reasonable inferences, then there must be doubt whether the inference sought to be drawn is correct."
	Mr Chairman, that is a cardinal rule of logic and in applying the test to proven facts here, in contradistinction to speculation, the applicant's version that the intention was only to damage that building, it is my submission, cannot be refuted. 
	It is my submission that although there were persons in the building at the time of the bomb went off, it is clear that there's room for a mistake, even perhaps negligence on the part of Van Zyl, Botha and Hardien.  It is clear from that evidence, it was put to the witness, Mr Alexander, the statement of Mr Williams that he had made at the time.  It was put to Mr Alexander, the evidence of the soccer players.  It was clear from his evidence that the Kewtown Youth Movement had actually left the building, that it is possible that someone could have thought that those people had left after the meeting had been adjourned, and that nobody in the position of Van Zyl, Botha or Hardien, would have known that the other people were coming to have a meeting, because they had got together across the street at the hall and only there decided that they would go and have the meeting at that particular time, at the hall. 
	So the effect of that is that the Committee driven to a conclusion that the applicant, insofar as he is concerned, has made full disclosure of the relevant facts.  
	Mr Chairman, that concludes my submissions and ...  Yes, and as my instructing attorney says, Mr Chairman, he's come here, he's made disclosure of these facts, why would he not make full disclosure?  He made full disclosure in regard to worse incidents, for instance the Nietverdiend incident, the Ribeiro incident, where he was peripherally involved only, but those are serious matters and amnesty was granted there to all the applicants in those particular cases.  Why would there not be a disclosure in this particular case where no real life danger was done to any of the people?