MR MOHLABA
Thank you, Chairperson. Briefly. Chairperson, the applicant has testified that he was recruited during 1990 by Shadrach Fundisa to be a member of the ANC and he was assisting in organising the ANC and worked as a
marshal in rallies. We heard that the deceased was at a certain stage a member of the ANC Youth League himself, but subsequently joined the Eagles which subsequently became the Stechers Lovers, which was a gangster. 
	We also heard that the deceased was a leader of this gangster movement and at one stage he tried to recruit the applicant to such a structure without success. We heard that the community complained to the ANC about the activities of the gang and that the applicant viewed such a complaint by the community members as a sort of a symbol of approval by the community of the elimination of the people involved in such atrocities in the community.
	On the date of this incident, it appears that the applicant and his brother were approached by the deceased and some other persons and a scuffle ensued. And it was not very clear from the applicant's side whether he relied on self-defence but on further questioning it transpired that self-defence was in fact an element as well, but he all along had a desire to eliminate the deceased.
	And it became very clear that the deceased was attacked and stabbed whilst lying on the ground and very clearly the deceased was no danger at all to the applicant at the time, and it was not necessary for the deceased, for the applicant to proceed and behave as he did to kill the deceased, if he did not formulate an intention earlier to kill him. So, it is very clear that the bounds of self-defence were exceeded by the deceased but with a motive. And such bounds were deliberately exceeded because of a political motivation, that is the deceased was always viewed as an enemy of the community and, given a chance, the applicant would have killed him. But it happened at a moment when the deceased made the first move. And in trying to defend himself, which he successfully did, he stabbed forward, that is proceeding to kill the deceased when he was no danger at all.
	So, this confirms his testimony that he, in any event, intended to kill the deceased and the reason for killing the deceased is none other than to eliminate him, because he was an enemy of the community, that he was a member of the gangsters.
	Chairperson, the question of the, the omission by the applicant in trial court to mention certain things, that this offence was politically motivated, could not be clearly articulated by the applicant himself. But the subsequent, that is the brother who came as a witness, sort of gave an indication to the Committee that during those moments, it was not easy to come out and it should be common knowledge to the Committee that the mere mention that we belong to a political organisation such as the ANC, would have, in fact, been an aggravating factor. They should have been viewed in a particular way by the trial judge. So it is true that the only way to get the leniency of the court was to conceal such very material facts.
	It is, therefore, my submission that the requirements of the Act have been satisfied and the applicant should be granted amnesty. Thank you, Chairperson.