MR RICHARD
Chair, may I proceed.  My first point is that between the 21st of April 1997 and the 14th of June 1986, number one the applicant was an accused in a very lengthy, hard and well fought trial and other trials had happened.  Mr Derrick McBride, his father, and Mr Lecordier, Mr Gordon Webster and in those proceedings much evidence was led.  The second point is whatever this document or statement or application is, or was, it was confirmed by him under oath in response to the questions put to him at the Section 29 enquiry.  The third point is what is now clearly common cause is that his applications for amnesty and the matters dealt with at the Section 29 enquiry, are the same.  In other words the Parade Hotel incident.  In other words he has given evidence on oath in relation to those incidents.  Then I have no difficulty in the circumstances, that as at April the year before last, the fifth applicant was able to make the statement during the car bomb operation at the Why Not bar, three people were killed and 69 injured.  He made that under oath.  It is an admission which he is bound by and which he cannot withdraw.  It is an admission of fact.  He goes on to say
"... those who were killed, were Marchelle Gerrand, Angelique Pattendon and Julie van der Linde."
	They are names that must have been bandied about the court rooms at length.  And then he proceeds to say -
"... for the list of those injured, refer to the trial record and charge sheet."
	And then adds on as an afterthought, but it is a particularly relevant afterthought -
" ... further details are contained in the application handed into the Commission in Durban at S29 hearing."
	I believe that the only consistent inference to be drawn from that parenthesised add-on is that  what he is referring to is the overall picture, not something relating to some minor aspect.  Now, where it takes this argument is that what is set out in Exhibit C and all the matters arising there from, are common cause with this current hearing, parallel thereto and intertwined and my submission is irretrievably so and it is impossible to separate the two.   I then turn to the questions of law.   At page 8, at paragraph 3, I deal with the first issue.  What is the nature of the information contained  in Exhibit C?  Now, Section 29 has a particular word in it, that which is furnished.  Now I have gone at length at pages 8 and 9 to detail how this hearing is a hearing in terms of the Act which is governed by the provisions of Chapter 6.  Exhibit C has been furnished in the plain English meaning of being provided firstly to the Committee, secondly to me and thirdly that if one embarks on a careful analysis of Section 29(5), that Section and I would then proceed to refer to an appendice to my Heads of Argument, the last page thereof, the power, the authority of the Commission to prohibit the making public of the information emanating from a Section 29 investigation ends when the document, information, article has been and I will use the word provided as opposed to furnished, at a hearing that at has historically now happened.  It is a past fact.  Whatever power the Commission might have had prior to the furnishing or providing of Exhibit C and everything emanating from it, is now at an end.  It is a public document which as I have outlined in the document before us, my Heads of Argument, which now falls in the public domain.  There is no restriction on any one picking it up from the table here and taking it and publishing it.