ADV MEMANI
Mr Chairman, I wish to deal with the matter of Mr Venter. It is common cause that Mr Venter - that Mr Ngo was an informer handled by Erasmus. On the version of Mr Ngo, he was introduced to Mr Venter by Mr Erasmus. However, Mr Erasmus has denied having introduced Mr Ngo to Mr Venter. One finds this denial difficult to accept. Firstly, Ngo was an informer of Mr Erasmus on matters occurring in black townships and black schools. Mr Ngo then moves, apparently without notifying his handler, to another address. He then leaves that address and later he informs the handler that 'I am leaving to a different place now, you must come and see me there'. I find that improbable; one would expect that the Security Branch would require of their informers to remain where they are and when they have to leave, when the leave the place where they are living to at least inform them that they are about to change their addresses.
	Mr Chairman, one also would expect the Security Branch to want to know the type of person their informer is living with. That would then have prompted Mr Erasmus to make some enquiries about Mr Venter. From what he told us he was not bothered at all. That is an improbability in my submission. I am sorry to repeat then; one would expect that some enquiry about Mr Venter should have been made.
	On the other hand, Mr Ngo gives a plausible explanation for his living at Venter's house. He says, 'I was living in the township until the day I became exposed; from that day onwards the Security Branch decided that I should live with Mr Venter'. That's the most plausible explanation. Mr Venter was a white person, removed from the black townships and it could not have been easy for schoolchildren to reach Mr Ngo at Mr Venter's house. So on this aspect the probabilities favour Ngo. This probability is strengthened by the fact that despite the fact that an allegation was made very early that two members of the Security Branch took Ngo to Mr Venter's house, when Mr Erasmus testified it did not appear he took any steps to ask from members of the Security Branch, 'who of you, by the way, took Ngo to Mr Venter's house?' Secondly, none of the persons who testified here and were implicated by Mr Ngo, said that they ever took Mr Ngo to Mr Venter's house.
	Mr Chairman, in my submission, if Ngo had been simply incorrect about the identity of the persons who took him there, we would have expected some correction.
	It was suggested that Mr Ngo went to live there because he was a gardener and helped in the house. Mr Chairman, I find this to be somewhat difficult to believe. At that stage Ngo was a schoolchild. I am not aware, since the time I was born, of anyone who employs a gardener who is a student fulltime, or one who employs a man to do internal domestic work like washing dishes and so on. I am not aware of those things.
	Some suggestion was made by Mr Erasmus that Mr Ngo apparently had a homosexual relationship with Mr Venter. Mr Chairman, if you look at the affidavit submitted on behalf of Mr Erasmus, it is in chronological order. If you have listened to the evidence as a whole, you will see that at the time when he made the affidavit he intended to lead us to believe that he had discovered that Mr Ngo had a homosexual relationship with Mr Venter before the trial. If we look at how the incidents are put there, the trial emerges much later.
The impression that one gets is that he discovered before Ngo went to Pretoria that he had a homosexual relationship with ...[intervention]