MR SAMUEL
IN ARGUMENT Thank you, Mr Chairman, Ladies and Gentlemen.  I submit that if one looks at the evidence before this Committee today, which to a very very large extent has been corroborated in substantial and material respects by the Judgment of Judge Nicholson.
	The picture emerges that just prior to the 1994 elections the area of Bottlebrush became ungovernable due to the rise in prominence and in numbers and in strength of a gang known as "The Mafia" gang.  
	The area which was an exclusive ANC area and had an ANC branch formed in it, the community looked to the ANC to provide the governance that was lacking from the government of the day.
	Various efforts were attempted, including resorting to the assistance of the police and no help ...[indistinct] the way of the community.  The community tried its own endeavours, firstly by talking to the parents of the criminals concerned, in some instances assaulting them and in some instances banishing them but the problem didn't disappear.  The entire situation became unbearable and when the two young girls were raped, the community almost ...[indistinct] passed a sentence against these people.  
	Looking at it in retrospect, as Judge Nicholson pointed out that the death penalty has in fact been declared unconstitutional, but one must look at the prevailing circumstances at that time.  The community had no other option, they tried every other available means and it was the responsibility of the ANC to provide leadership and get rid of the criminal element.  	In that instance the three applicants were acting in furtherance of a political purpose, that is to provide governance which was lacking by the government of the day.  And in those instances I submit with respect, that the applicants have made out a case for amnesty and their actions were political and were necessary, given the circumstances that prevailed and the time and era in which it occurred.
	I'm therefore asking with respect, that the three applicants be given amnesty.