ADV MEMANI
The only suggestion that we have is that until November he might have been in Bloemfontein, but December and January we can't say that he was in Bloemfontein. In December and January, especially January and early February there is no suggestion that he was around; he probably had been in Pretoria at the time.
	Mr Chairman, the next aspect is the evidence of Mr Ngo regarding how the body was disposed of. This is a very difficult aspect of the application. It is clear that no submission can ever made that the explanation was satisfactory.	The next question is, how does that affect his application to make a full disclosure? I would venture to suggest that in these circumstances one must ask oneself whether Ngo deliberately attempted to conceal his involvement in the disposal of the body. In my submission there is substantial compliance with the requirement of full disclosure in this regard in that, despite the fact that he is not satisfactory - his evidence is not satisfactory on matters such as how there came to be a wire and on matters such as whether the brothers would not have been surprised by the wire around Mr Venter's neck, in my submission these are matters which are related to detail rather than matters that relate to an unwillingness to involve one's involvement in the commission of an offence. I want to suggest, Mr Chairman, that you should imagine the situation if, for instance, Mr Venter's whereabouts were not known at the time when the application was made. His evidence would have allowed you to reach and find Mr Venter's body and know where it was disposed of. All in all what I am saying is, Mr Ngo gave a full account of what occurred to Mr Venter from the moment when he shot him right up to the moment when Mr Venter was found.
	Mr Chairman, in weighing the evidence as a whole, one must have regard to the fact that there has been this general pattern of denial of all incidents or most of the incidents in all material respects by the police. It is improbable that Mr Motsamai incorrectly implicated any of the policemen. The denials of the police must be seen in the light of the fact that it is known that during the era in which these things are alleged to have occurred by Ngo and Motsamai, the police themselves have admitted that the situation had become such that legal means of suppressing resistance were not sufficient and the had to resort to unconventional means. One does not have any reason to understand why the police in Bloemfontein would have been immune from this pressure and the temptation to do something, something which might be illegal. Their denials anyway are not borne out by the evidence that has been led in these applications.
	Mr Chairman, lastly, in the assessment of the evidence of Mr Ngo generally one must recall that these things occurred today about 14 or 15 years ago, starting from the 1984 incident. Most of these incidents appear to have occurred within the space of about two to three months only, and it appears that in that short space of time Mr Ngo did an awful lot in both senses of the word, and some of the inconsistencies of his evidence should be understood in that context. Those are my submissions, Mr Chairman.