UNKNOWN
Firstly the one incident where the evidence was that it happened in 1995.  In the statement given by the applicant he mentioned before the election 1994.  I would ask the Commission not to make a finding on that, whether it fell within or without the cut-off date before all the information was gathered by Mr Brink.  There were some inconsistencies in his evidence especially where dates and times etc., was not, could not be remembered but it is my submission it happened some time ago, at least four years, five years ago and it is a number of incidents and where he could not remember or he could not give exact details or where it seems he might have contradicted himself it might well have been as a result of the long time period and the number of incidents in which he was in fact involved, that some of the details got confused.
	It is my submission that the actions that he did perpetrate was according to his evidence for political motives.  He was instructed by this Nyawuza to commit certain acts on behalf of Nyawuza for Nyawuza's political gain and then to assist the IFP in winning the elections.  Also the evidence he gave later on regarding the SPU's etc, he had a bona fide belief that what was done was for the political gain of the IFP.
	It is my submission he did tell the truth, although sometimes he was not all that really clear as I have already stated.  He might well not remember everything as clearly because he is not a well-educated man it seems from the fact that he is not able to read English, his thumb print was annexed to his affidavit, etc.  Therefore I have requested the Commission to make a finding that he was truthful in what he did say to the Commission. 
	The one aspect that might cause a problem  is Section 23 (f) 1.  It is my submission that he was a member of the IFP even before he joined the SPU.  He did say that the only reason for his actions was to get employment and for the money. I don't know whether one can take this into Section 22(b) or (c), I'm sorry, (c) or (d) as being employed to do this. I will leave that in the hands of  ...(intervention)