MR DEHAL
Thank you Mr Chairperson.  Mr Chairperson, as I understood the argument yesterday, the inquiry appeared to fall outside the purview of what is today being discussed. Yesterday my learned colleague, the Evidence Leader, premised his argument on the basis that Mr McBride referred to his 29 proceedings in his application for amnesty, and that is the reason why he caused those copies of the evidence to be included in the bundle before us.  Now I think he is acting in good faith, I see reason for him to have acted so, I have no argument against him, but wrongly, he has acted wrongly.  Surely, not in bad faith.   In so far as Mr Richard is concerned, I understood his argument as being premised on privilege and so he went about Hoffman and privilege and the document falling in his lap and hence the privilege waived.   I see today that the argument deals principally with the Act and the legal submissions, I will deal with them all briefly.  I think it would be important to deal with yesterday's submissions for the inquiry I submit respectfully, is  wider.   My submissions are that one must have regard to the application for amnesty by Mr McBride and the reference therein to the, albeit ambiguous terminology relative to the evidence in the 29 hearings.  May I take you Mr Chairperson and Honourable Members to page 103 of bundle A1 and ending at page 112, that is the application for amnesty by Mr McBride, page 103 onwards.  Mr Chairperson, you will notice that this firstly is an application for amnesty by Mr McBride himself, this is an application formulated not on the roneod form, but on a form that has been captured onto Mr Currin's computers, to keep the roneo'd format the same, but to fill in details.  What is important is not that, but this.  Mr Chairperson, you would look at page 104 and paragraph 9(a) which deals with the acts itself.  In dealing with the acts and various counts for which amnesty is being sought, no reference is made to any aspect relative to the 29 proceedings.  He refers to it only under paragraph (b) on page 106, but of course it is referred to on the following page, page 107.  It is important to understand this document and the reference to the 29's aspects, not the proceedings but aspects, within that context.   9(b) deals not with the acts, but purely with the injuries and deaths resulting from the above.  (i), (ii) on page 106 and on page 107 (iii).  (iii) Mr Chairperson and Honourable Members, deal with the following - principally the car bomb operation at Why Not bar and in particular confined to a list of the persons who were injured or killed as a result of that operation.  Now to obviate the need to type out a list of those names or injured and deceased persons, Mr McBride seeks to refer in the first place to the trial record and charge sheet and then to the application and look at those words specifically, he says in parenthesis "further details are contained in the application handed in to the Commission in Durban at Section 29 hearing", he does not say look at my evidence.