MR BERGER
Yes and defective means no substantial compliance.  About illiterate people not being able to submit the applications, the applicants - I don't know whether they are illiterate - Mr Mthembu surely is not - but they had legal representation throughout, they've had legal representation since 1994.
	Question of balancing prejudice and that prejudice is evenly balanced - with respect, this is not a question of balancing prejudice.  The question is whether vested rights are being taken away.  The applicants had their rights and they had the power to preserve their rights.  Their own actions meant that they forfeit those rights.  The victims have not had the power to preserve their rights, they rely on the provisions of the Act.  Mr Khubeka's application can be supplemented now and he will then have a valid application before the Committee.  With respect, that highlights the absurdity of the argument of saying that the applications can be - the defectiveness can be cured at any stage.  The defectiveness cannot be cured at any stage - there must be valid applications as at per cut off date otherwise Mr Khubeka could come in ten years time and say I want to now give you my story and the Committee would be bound to hear him.  That can't possibly be correct.
	And finally, as far as the purpose and spirit of the Act is concerned, yes, the purpose of the Act is to get at the truth but the purpose of the Act is also to set limits so that there can be justice between the parties.  The applicants had their rights, they forfeited them, the victims have their rights and they stand on those rights.  We would ask that the applications be dismissed for want of compliance of Section 21 (a).  Thank you.