MS LOCKHAT
Chairperson it's my submission that the amnesty applications of Alfred Ndlovu, John Sithole, Elias Mbatha and Mr Mpongosi be refused amnesty on the basis that they failed to make full disclosure to the Commission.
	The fact that they submitted amnesty applications in 97 and failed to give full account of their actions and their involvement in the incident, from the fact that, taken from Mr Sithole's evidence, the fact that he said that the AK-47 was his, and then later in the evidence he said that Mr Magwaza had handed it down to him and was due to their leave, application for leave to appeal to the High Court, it seems improbably that this was indeed the position and that he's lying today still.  Or today he's telling the truth and previously he was lying.  And that he also covered up for Magwaza, and that on that basis the fact that at the High Court he said he denied committing the offence, and then making the submission that he had the firearm, and that it was his, actually was prejudicial as well to his High Court application and his leave to appeal. 
	And then I can go on further to Ndlovu's application where he doesn't give full disclosure from the outset, Chairperson.  The fact that he failed to include the Skosana's shebeen incident in his first application, was a huge mistake on his part, and he made that at his own peril, and the consequences of that is also not full disclosure.
	The same would go for Elias Mbatha and Mpongosi.  The only statement they made was that they were acting in self-defence and not accounting that they both had firearms, and that they actually went out on that specific day and shot, and that is real material, a material omission on their part, to take the Commission into their confidence.
	And on that basis Chairperson, it is my submission that these amnesty applications should be dismissed and refused amnesty.