MR RICHARD
Yes.  I don't think it's our job to try and destroy the conviction so as to prevent giving him amnesty, because that would be in fact a defeat of the purposes of the Act.  The same way as my argument about mental competence.  If your going to use those strict arguments in law to eliminate competence to bring it, it makes a mockery of the idea of amnesty, and it defeats the objectives of the Act, and that is to put the past behind us by giving amnesty where it can be properly given.
	My interpretation of the Act is on a wide and liberal interpretation, but I don't see how anyone could argue that it should be a strict and narrow interpretation.  One need only reflect on the case of Azapo vs The President of the Republic of South Africa.  There the limitation is not seen from the language of the Act, it's seen only from the language of the protection and interests that the Commission should give to victims.  In this particular instance there is no argument that the Act is disproportionate, as I understand it yet - I haven't gathered it from my learned colleague's cross-examination, or that the force or violence was inappropriate, or that there was no political context as opposed to political motive for 
what was done.  Certainly when it comes to Daniel's situation, there was a political context.  These reports establish it without us going through it.  And for those reasons, my submission Chairperson, is that the widest reasonable interpretation of the Act should be applied, which would favour an applicant such as a person in Daniel's position.
	In conclusion, my argument is that in the case Michael Phasha, the requirements of the Act have been satisfied.  The act was proportional, it was an act which constituted a crime committed during the struggle, for the purposes of the furtherance of the interests of the ANC, and there's not an iota of evidence before us that the ANC does not accept that it was done for the furtherances of its interests.  It may well say it would have preferred not to, but it's not the test.
	The subject of tests, flowing from (l) of Section 20(f), I think, of Section 20(2), I think it's plain that Michael Phasha certainly believed he had the authority to do what he was doing, even though it might not have been a rational logical belief.  The hysteria of a crowd chanting freedom slogans and in high blood so as to eliminate a perceived enemy of its revolution, would endue such a belief.
	In conclusion, in relation to Daniel Phasha I repeat the arguments, it would be absurd to interpret common purpose in such a way as to hold that there is no valid conviction and that while the applicant does not concede that he was guilty by way of common purpose, I believe that despite his objection to being associated, he should be associated with the crime ...(intervention)