MR BERGER
Chairperson, the point I'm making is that form 1, which is the requirement in terms of the Act for the launching of an application was resubmitted afresh in February 1998.  If the applications and even if there is a connection between this document and the previous document, my submission is that the applications must stand or fall by what was submitted to the TRC prior to the cut off date and I understand my learned friends' heads of argument, at least we're agreed on that, that the validity or otherwise of the applications must be judged in the light of a document which was submitted timeously.  Now the Committee has a copy of one of those applications and we have been told that they are all identical.  Our submissions are that Section 20 of the Act sets up three jurisdictional requirements for Amnesty.
a)	 That it must comply with the requirements of the act, the application.
	b)	That is must be an act associated with a political objective
	c)	That there must be full disclosure.
The basis of the argument is that those are three separate jurisdictional facts, each of which has to be satisfied in order for the Committee to be in a position to grant amnesty.
	The Act in Section 20 says that if the Committee is satisfied on those three jurisdictional facts then it shall grant amnesty.  The use of the word "shall" is instructive because it would seem that at that stage, once those three jurisdictional facts are satisfied, then the Committee has no option but to grant amnesty, hence the use of the word "shall."
	However, it's the basis of the argument that if any one of those three jurisdictional facts is not satisfied, then in our submission, the Committee does not have the power to grant amnesty.