MR MBANDAZAYO
Mr Chairperson, I would repeat to quote the requirements of Section 20, suffice to say that my submission is that the applicant has met the requirements of Section 20(1) and (2), that at the time of the incident, he was acting on behalf of APLA, a publicly known political organisation and liberation movement, which was engaged in a political struggle against the State at the time.
	Also that the applicant did not act for personal gain or out of malice, ill will or spite, directed against the deceased.
	Mr Chairperson, I will start with the first incident.  It is clear Mr Chairperson, that the applicant was a foot soldier, he was given an order by a member of the High Command of APLA, which was the decision maker within APLA, that they have evidence that Mr Meheza was acting as an informer, and that he was sabotaging the activities of the organisation and has to be eliminated.
	Mr Chairperson, if I may refer the Committee to the Court judgement, if one follows the judgement of the Court, indirectly it was admitted by the State when it was argued that he must be punished severely because he killed an informer.