MR VISSER
Thank you, Mr Commissioner. Broadly speaking, the matter has to be approached on basically two bases to which regarded has to be had. The one is the requirements of the Act and the other is of course the evidence. I'm not going today to discuss the evidence with you, but what we intend to do is to approach our argument to you on those two bases, and if I may say that in regard to the first section, the question of the requirements of the Act, we believe that what is important there is to draw your attention to what precise measure of proof or standard of evidence it will be expected of an applicant to give before this Committee. Then, most importantly, what is the precise basis of the applications now before you on the evidence of the applicants. That will entail, Mr Chairman, the question of whether both applicants at all times could have been regarded as 'member of the Security Force'. Then, of course, the last aspect in that regard is that there is also the qualification that the acts or offence had to be directed against, and then the sections are set out.
	As far as the evidence is concerned, Mr Chairman, we will on paper present to you the dissecting of the evidence un der four headings; first of all, matters which are common cause, which will search through the records and placed before you. Secondly and tying in with that, matters which are objective facts which cannot be denied and must be accepted. Thirdly, we will discuss the probabilities which my learned friend Mr Stander has done this morning, and my learned friend Mr Memani. Lastly we will deal with the credibility of witnesses.
	Mr Chairman, I'm only going to deal with the first aspect, the requirements of the Act to lay some thoughts in your midst as to how this matter, according to our submission, ought to be approached.
	First of all, as to what standard of proof has to be put before you, Mr Chairman, of course the Act is silent. The Act speaks in s 20 that the Committee must be satisfied. That begs the question, of course. Does one apply the normal standard of the balance of probabilities, or is it something less? We would submit, Mr Chairman, that most appropriately the ordinary accepted standard of proof on balance of probabilities should be the most acceptable standard if only by reason of the fact that it has been applied for many, many years and that there is some clarity about what standard of proof entails.
	We know from our case law in all matters which allowed for a discretion to be exercised upon a person being satisfied or a judge being satisfied, there have been legal arguments and there has been a diversity of opinion. What the Act says is, you must be satisfied. We say, Mr Chairman, it could be on a balance of probabilities or something less. It is going to be something less, then of course it depends on the person to person and how each person sees a certain situation. We will address you on that basis, that it is perhaps something less. We will take it against us without conceding that ...[intervention]