UNKNOWN
I'm turning to disclosure of all relevant facts.   It is submitted that the applicant has disclosed all relevant facts.   It is furthermore submitted that relevant facts mean, the facta probanda" in respect of criminal offences and the principles of a delict in respect of delicts.   These requirements have been complied with in the evidence pertaining to each and every incident.   It is submitted that where there is no evidence to the contrary, and where it was not put to any of the witnesses that any other witnesses would contradict the evidence, the applicant's evidence should stand uncontested and should be accepted as true and a full disclosure of such facts.
	Care should be taken not to be too harsh on the applicants in respect of their memories.   If one has due regard to the fact that a lot of the incidents have taken place more than twenty years ago, and that their memories have been affected.    
      It is furthermore submitted that the applicants had no reason to lie whatsoever.   It is submitted that it should be taken into account that Mr Beneke came forward out of his own free will to participate in this process to apply for amnesty and to place before the Committee the full version of the facts.   He did so without having been forced to do so and there should therefore be no reason whatsoever for him to have lied.   The only effect of a lie would have been the refusal of amnesty which would clearly not be to the advantage of the applicants.