MR DU TOIT
No, that - I think that follows from what I say, namely that what is the main object of examination here is the motive which sits behind the act.  The consequences, unthinkably tragic as they may be, will not affect that motive.  And it is for that reason why the Legislature has been very careful not to limit the granting of amnesty to those - to be blunt, to those  murderers, the murderers of exactly the people at which the Act was also aimed at motive-wise by the perpetrator.  That is why the - the requirement is one of association.  The requirement is one of making the object, the primary object even - there may be secondary objectives, but the
	/primary
primary objective to achieve a political aim.
You are also called upon to keep in mind the criteria applied in the two Acts repealed by section 48 of this Act.  Of course the first Act would not be applicable because he was not entitled to consideration under the first Act, but the '92 Act the criteria there will be applicable.  And there the wider criterion is clearly associated with a political motive.  
I must point out that it is here where the release of the other four perpetrators of the offence found guilty by WILSON J will become relevant, because the four special constables, who were not only convicted of a similar offence, but the exact same offence or offences, were released under that Act.  And I would submit that that is also a consideration which should weigh heavily with you since, in my view, the Constitution could never have envisaged inequality, in that the four special constables are released and that the officer who gave that instruction is not released.  I would submit that one is driven to an inference of inequality if people who committed the identical offence are, for purposes of amnesty, not treated equally.  And therefore I think in this particular matter the criteria applied in the Act of 1992 will be of specific weight.
There are other considerations not directly applicable to the facts.  One of these considerations must be the effect or the outcome of this application.  If you were to grant amnesty or early release here it will send out a strong signal to other members in the police force, in the defence force, past and present, to come forward and to tell everything.  I think that an early decision
	/here, a
here, a speedy decision to release, will bring about a  situation where other force members, as my client has in fact urged them to do, will come forward and will lodge their applications.  I think that it is necessary that those who have more information than my client should come forward.  I would mention members of the force who may have been involved with the Management System and various other strategies for much longer than my client would have been would also possess valuable information.  If you were to grant the application of my client there will be a solid signal which is sent out. 
That also would be in accordance with the declared aim of this Act, because, as, Mr Chairperson and Commissioners, you will no doubt know, the aim to establish the truth to prevent a repetition of such acts in future is almost at the heart of this Act.  And I believe that you would serve ... (intervention)