MR MBANDAZAYO
Thank you, Mr Chairperson.  	Mr Chairperson, I would not go through the provisions of Section 20(1) and (2), as it is well-known to this Committee.
	Mr Chairperson, the applicant in this matter has testified before this Committee and told the Committee that he was a supporter of the Pan Africanist Congress, he was recruited by Mr Masilela and that he committed the offence, that is that of escaping from prison and that of robbery in prison at the instance of Mr Masilela who was a member of APLA and as such a member of the Pan Africanist Congress of Azania, which is a known political organisation in this country, who at the time was fighting for the liberation of the African people.
	As such, Mr Sapele acted on the instruction of Mr Masilela who also testified and confirmed that, that he recruited many people in prison, he was conscientising them, trying to convince them to dissuade from what he termed as criminal activities and join them in the liberation of the African people, and that Mr Sapele was the person who was so enthusiastic about joining APLA.  And as a result thereof they arranged that they escape from prison to go to Zimbabwe and that also Mr Sapele to undergo training. 
	Mr Chairperson, it is therefore my submission that the applicant has complied with the requirements of Section 20(1) and also (2), that at the time he was quite acting on behalf of APLA at the time, which as I indicated was a publicly known political organisation which was engaged in the political struggle.  And that when he acted he did not act for personal gain nor out of malice but he bona fide acted on behalf of his organisation, which was PAC.
	Mr Chairperson, Mr Sapele, one would argue that at the time he joined APLA and that is was only Mr Masilela who was a fully fledged member of APLA at the time, and Mr Masilela was in prison for that reason, being a member of APLA a what Mr Masilela did in prison was in continuation of his struggle to fight against the regime at the time.
	Mr Chairperson, my argument is that Mr Sapele was in prison for criminal activities and he does not deny that and he does not deny that at the instance of Mr Masilela as he was serving his prison sentence, he was recruited by him.  At the time he acted and tried to escape from prison and committed robbery, he no longer involved in criminal activities.  At that time he acted as a member, as a supporter of PAC and an aspirant member of APLA, as what he did was trying to join APLA outside.  
	And as such what he did in that particular time, trying to escape from prison and the robbing of the money, the money which was going to be used as a mode of transport to their destination, which is they were going to Zimbabwe, they wanted to leave the country so they wanted money and that money was to be used in pursuance of that objective, that one of being part of the liberation struggle.
	And it is therefore my humble submission, Mr Chairperson, that the applicant has fulfilled the requirements of the Act and that he has made full disclosure with regard to his activities on the day in question and as he has been conferred to by Mr Masilela.  As such it is my humble request that this Committee should grant amnesty to Mr Sapele as applied unless the Committee wants me to address it on a specific point, Mr Chairperson.