ADV TSHONGWENI
That is correct, Mr Chairman.
ADV TSHONGWENI ADDRESSES COMMITTEE ON MERITS OF CASE
	Thank you, Mr Chairman. With your permission I would like to give a brief address on behalf of applicant No 2, that is Simon Moalosi.  
	May it please the Chairman and members of the Committee.  We have just heard evidence by the applicant which its nature is that No 1, he was a member of the Correctional Services which was then called Prison Services. In terms of Section 1 of the Promotion of National Unity and Reconciliation Act, security forces is defined as including members of the Department of Correctional Services.  So I will argue that he fits the category of the definition of the Act. 
	He committed a gross violation of human rights, that is killing as defined in the Act, and he has adduced evidence to that effect.  The applicant also believed that the ANC supporters were his enemy.  He also adduced evidence to this effect that during one of the stayaways, which was called by supporters of the UDF or African National Congress, he did not heed the stayaway call.  As a result he was assaulted by ANC supporters, who viewed him as an enemy. 
	The applicant's act, I would argue, that it is associated with a political objective because it was clear that at that time in Parys, Tamahole township, the ANC supporters were hostile towards him, because they viewed him as the enemy. In fact, the act was committed in the course of the conflict between the ANC supporters and those who did not support the ANC.  One would appreciate the fact that one, if you are a member of the community at Tamahole, you were either regarded as a comrade or an enemy.  Unfortunately for the applicant he fell on the side of the enemy. As a result of this conflict. 
	Although he committed the offence without an order or an instruction as required by the Act, it was clear that if he did not defend himself at that time against his political rivals or opponents, he would have been seriously injured or killed.  He didn't know what would happen the following day because there was this tag hanging on him, that he was an enemy.
	In conclusion, Mr Chairman, I have briefly stated that the situation in Tamahole at that time was that one would be either on the side of the comrades or the security forces, as defined in the Act.  The applicant has so identified himself as an enemy, because he never heeded to the calls of UDF supporters or ANC members.
	With your permission, Mr Chairman, I would like to narrate an extract from the ANC's statement, which was submitted to the Truth and Reconciliation Commission.