MR LANDMAN
Mr Chairman I would just also recall the evidence of the first applicant where he stated that all he had to do was simply to ensure that the battery was attached, otherwise the explosives were ready, it was properly prepared and clearly it was prepared by person with military knowledge.
	Mr Chairman we submit that the first and second applicants testified as to the motives of the first applicant, Mr Chairman this being one of the criteria, and to a lesser extent - this is on page 15, paragraph 18 - and to a lesser extent the motives of the second applicant in committing and participating in the planning of the act.  
	Mr Chairman the first applicant evidence was that he was carrying out the instructions given to him by his MK Commander, Nyanda, and was thereby advancing the objectives and policies of the ANC which were inter alia to attack and afflict injury on South African Police personnel.
	Mr Chairman similarly the second applicant's motives in training the first applicant in the use of explosives and supplying such explosives and the remote control were similarly to advance the policies of the ANC and MK to take the armed struggle to the White areas and to attack members of the South African Police.  Mr Chairman we submit again the fact that the second applicant was in exile and was part of the MK command structures, again re-emphasises the fact that this was, that the motive was to further the aims of the ANC at the time.
	Mr Chairman as was pointed out in Gerber case, the guidelines published under the Indemnity Act of 1990 are also to be taken into account by the Committee in terms of Section 24 and Mr Chairman the reason why I refer to that is because the guidelines in that case are - in some cases are slightly more explanatory and when dealing with the guidelines, one of them is the motive of the offender, that is to say if it is an offence that is committed with a political motive in mind for example to advance the objectives of a political organisation or whether it was for a personal motive.  Mr Chairman our submission is that clearly this was with a political motive in mind.
	Mr Chairman as far as the context within which the act occurred we submit it is clearly within the context of an armed struggle which had been moved into the white areas and that members of the South African Police were at that stage considered to be legitimate targets in terms of ANC policy and again I make the point I'm not suggesting that they only became legitimate targets at that particular point.