MR WILLS
I would go so far as to say it was policy, in the sense that it relates to what Mr Stewart and what Mr Luthuli brought out as regards the public and the private face of the Inkatha's tactics.  I submit it was used so commonly that what might have been a practice certainly developed at least, at the very least, in the minds of the applicants, to be a policy of the organisation.  And from a very young age Inkatha youth, particularly Hlongwane were, and applicant four Ndlovu, taught that you had to be a member of Inkatha to live in this area.  And being a loyal member of Inkatha you had to, you had no choice, you had to attend at camps, you had to obey the instructions of military commanders, and you had to chase the ANC out, or the UDF out of the area.  So I'd submit it was a policy.
	In regard to this, going to page 7 of my Heads, in view of this territorial, this territorial nature of the conflict, and in view of the fact that all the applicant who I represent were involved in this military attack, it's my submission that all the applicant believed, on reasonable grounds, that they were acting within the course of their duties, or with express or implied authority as IFP hit men.  And I submit that the evidence of Luthuli reinforces this point.
Another important aspect is the specific hit squad that was set up at Izingolweni dealing with Izingolweni matters.  Here what was important was that applicant five was called to Ulundi, spoken to by very senior IFP people, and asked him if he'd be capable, if he, well he was ordered in fact, to set up a hit squad.  He then was given the task to recruit other people and he was informed how things would basically operate.  He appointed first of all applicant five Mbambo, and then later on Hlongwane was sent on instructions by Luthuli to join, and so to was Dlamini, applicant three, to join in.  The significance of that, from my point of view, from the evidence it can be seen, is that at least in relation to those people acting below Mkhize, and in every event wherein Mkhize were involved, they had orders from Mkhize, and Mkhize obviously got his orders in the main from Captain Langeni.  And the Committee Members will recall the main person who was communicating with Ulundi, and in fact with the local IFP leadership whose role was mainly to identify targets, was in fact Mkhize, and to a lesser extent, at least with the local leadership, was Mbambo, who in fact, when Mkhize was available, took over for a short period as the leader of the hit squad.
	On page 8 I refer to the modus operandi, the identification and  elimination of specific targets, and the indiscriminate attacks on ANC areas and persons.  The only issue, I think that it would waste the Committee's time for me to go through the actual incidents, I've documented them here in relation to Izingolweni, the only thing that I want to touch on is the so called what I've termed the cross fire cases.  	You will recall that there were a number of incidents where, for example in the murder of Sergeant Dlamini, Sergeant Khumalo, where Mr Mabiko was killed.  You'll also recall the incident where there was an attempt on Mr Ntimkulu's life, and it turned out that there were in fact women in the car, and Mr Ntimkulu was nowhere to be found.  It's my submission in those incidents that the motivation was still political in the sense that they went out to perform those deeds, and secondly that because the deeds in the main occurred within the context of this territorial conflict, that they were relatively certain in any event that the persons found in those areas would be ANC supporting.  And so in a sense the two types of attacks dovetailed, and weren't outside what the policy of the military strategy was.
	What's also important from, from my clients' point of view, is the fact that they invariably reported back the incidents to, usually in the case of Mr Mkhize to Ulundi, and always to the local leadership in Empangeni, usually either to the, to Mr Bhiela or Mrs Umbuyazi.
Mr Stewart referred to the issue of the kidnapping and murder of Natie Gumede.  Clearly from the, the evidence suggests and it's not contested in any way, was that there was a direct instruction given at a meeting in Ulundi by Prince Gideon Zulu whose a very senior person within the IFP, that this person should be eliminated.  Not only did he give the order but he also ordered his subordinate, a Mr Naiwozi to organise a car from the chief minister's department, and the car was utilised, and after the attack it was, after the execution of the order, a report back was made.  There was, I remember at the trial, and also the suggestion in cross-examination that  there might have been an ulterior motive particularly from Mbambo, relating to the stealing of a car, but on balance the evidence clearly weighs in favour of the applicants that that was in fact no the motivation.  
	You will recall that a considerable time was spent in checking up the deeds and the activities of Gumede, before the decision was taken to kill him.  In fact Mkhize and Mbambo conducted certain investigations and only after they were satisfied that this was in fact an ANC plot, when I say they were satisfied within their own minds that this was an ANC plot to have Mr Mbambo, who was well know in Izingolweni at the time for what he was doing, taken off the streets, and it was for that reason ...(intervention)