MR ALBERTS
Thank you Mr Chairman.  Mr Chairman it's my submission that the two applicants did comply with the requirements of Section 20 in that there was surely full disclosure, they told the Commission exactly what happened at the time.  The one aspect regarding the mini bus taxi, there was a witness called who somewhat contradicted what the applicants have said.
	Firstly the applicants merely related the information they believed to be true at the time.  It was information given to them and what they stated is that they believed it at the time and therefore acted bona fide.  Mr Mkhize also could not exclude the possibility that this Peta could have driven in the vehicle.  He doesn't know what happened with this vehicle while he is at work.  Therefore, that point as such should not be taken to mean that they did not fully disclose.
	The other point regarding the mini bus is, it's true that the Judge at the trial made, came to a different decision, it was on the facts or it was actually an inference that he'd made from the facts given to him at the trial.  The two accused at that time obviously were lying.  They explained to us why they believed this and they were telling the truth.  It's my submission that this Commission should not be bound by that ruling by the Judge.
	The fact that there were innocent people in the vehicle eventually, that was only realised according to the two applicants at a later stage while this attack was already under way and they decided to continue.  This should also not be a reason for them not being given amnesty.  It's my submission Mr Chairman that for example a person who plants a bomb at a restaurant, surely he doesn't know who h is going to be there or what those peoples' political affiliation, if any, is going to be or a person who plants a bomb in the street and the mere fact that it was in the end innocent people that died and that surely they should have foreseen the possibility that should also not be a reason for them not being granted amnesty.