UNKNOWN
That we submit that in order for the Committee to be satisfied that Section 20(1)(c) has been complied with.  The Committee must be satisfied that the applicant has been able to show on a balance of probabilities that he has told the truth concerning the relevant facts and we have already done that in the addendum.  I merely wish to state, Mr Chairperson, in general terms, that the claim by our learned friends in relation to a benevolent and liberal interpretation of the constitution.  These are general terms, of the purposeful interpretation.  Yes, as generalities they are correct but in relation to the specifics as to what interpretation must be given to the words or phrases in the Act, they should not be interpreted in order to deprive the constitutional rights that the victims have and that they should not be interpreted in a manner in which the effect is that on somehow or other principle grant amnesty if they've come here and they have told you some sort of a story.  That is not a proper interpretation of the constitution and it's not a proper interpretation of the Act.
	I want to go on to paragraph 46, Mr Chairperson.  The applicants claim that they acted as members of the Security Forces of the State within the meaning of Section 20(2)(b).  The evidence, however, is clear that the CCB was created and structured so as to ensure that the CCB employees were neither members of the Security Forces nor employees of the State.  It is true that the CCB was State funded but so too are many other bodies whose employees are not employees of the State.  Now I want to deal with the interpretation of the Act in support of this Mr Chairperson and if we have a look at B:
"Any employee of the State or any former State or any member of the Security Forces of the State."
Now quite correctly, your attention was drawn as to what is meant by Security Forces in the definition section.  It says"
"Includes a member or agent of the South African Defence Force, the South African Police or any of their organs."
But now, 22B speaks about employees or members in the Security Forces.  The word that we have to look for is whether there were employees or members and what we say is that on the facts they were neither.  On the facts they were neither.  We do not want to elevate this into a point of law, Mr Chairperson, that it is clear that they are not entitled to amnesty on this basis only.  But we submit that it must be taken into consideration that they were not employees or members in the ordinary sense of the word.