MR MBANDAZAYO
Chairperson, I wouldn't this time read the provisions, they are well-known to the Committee more than myself, the provisions of this section, suffice to say that, first to submit that it is my submission that the four applicants have complied with the requirements of Section 20(1) and (2) as they were on the day acting on behalf of APLA, a known political organisation and liberation movement which was engaged in political struggle against the State at that time.
	Chairperson I will start with the, my focus will be on the political objective sought to be achieved by the incident, and also on the full disclosure, especially the question of full disclosure.  
	Chairperson, I will start with the first applicant, Thembelani Xundu.  Chairperson, I think the Committee will agree with me on this aspect that also myself I want to concede in all the applicants, in all the incidents that I've represented the applicants on behalf of APLA, is one where I had one of the articulate applicants who were able to put the events across as clearly as they can. 
	Chairperson, everything that was asked by the Committee from the applicant, he answered it as clearly as he could and he took the Committee in each and ever detail regarding this incident.  He told the Committee that there was an order and that after that he was given a task to do reconnaissance, and he was the person who did the reconnaissance.  And took the Committee in all the details as to what he did, how he pretended to be a caddy in the golf club in trying to collect the information.  Every aspect, everything that was involved in the operation at the golf club he told the Committee every detail.  
	Chairperson, the only thing that I think cropped up when Mr Stanford's former attorney questioned him it's then that there was some hitches, was the question of the report about the incident where it was that it was postponed.  That was the only hitch that was there.  And he said that it was never postponed, the only operation that was postponed was one which was to be carried out at the sports fields where the South African Defence Force was going to have activities, and because of raid they couldn't and the report read that the enemy, because the enemy could not avail itself.  And he said that he believed that the report was doctored.  
	Fortunately, Mr Radie who was the organiser, who was involved in the whole thing, came and testified and told the Committee that there was not any stage that date was secured at no stage was this postponed, this event was postponed.  So in that aspect his version was confirmed by Mr Radie, that there was no way.  And it leaves only one thing that that report was doctored, that it included the other incident together with the golf club and it reflected as if the golf club incident was once postponed.
	And as such, Chairperson, that is the reason I first quoted that the applicant has met, when it comes to disclosure, Chairperson, there was nothing which came across to contradict all the evidence that he gave before this Committee.
	As well with the second applicant.  The second applicant came on to confirm and also his role with regard to that.  Thobela Mlambisa who was a driver, he told the Committee what was he doing before they carried out the operation, that they were involved in classes and they were waiting for the day that they have to, they knew that when they came, he came from Transkei, that he came here for an operation and that he knew that he was waiting for that.  
	All of them they were only doing political classes in order to get themselves ready for that, and that they were informed about that operation on the day of it and they were taken there by Thembelani Xundu and they were shown the place.
	It's the same with the third applicant, Chairperson.  The only role that he played, the only role that he played was to supply weapons.  Before I go to the third applicant, Chairperson, one would remember that Mlambisa was also involved in the St James incident.  So Chairperson, there is no doubt about his, the same with this operation, though it was the first one Chairperson, in these operations of APLA which are almost similar with the St James, Heidelberg and others.  It was heard first the St James.  Thubela Mlambisa was also involved in the St James incident which was after the golf club incident.  And also that on its own shows that the same modus operandi was the same at the golf club, which was the same also at the St James incident and the Heidelberg incident, Chairperson, though none of them were involved in the Heidelberg incident, these applicants.
	What I'm trying to get across, Chairperson, it's clear that if you look at the St James where he was involved and he was granted amnesty and also look at the golf club, these incidents the same modus operandi is the same and all of them were carried out in the same manner.  And as such, Chairperson, it's clear that all of them were politically motivated and that all of them were clearly operations of APLA, as all of them like St James were claimed by APLA, and also PAC has taken upon it also that of course APLA was responsible for this operation.
	Also coming to the third applicant, Moalusi Morrison.  Chairperson, the role that was played by Moalusi Morrison was to supply weapons and that he told the Committee how he ferried weapons from Transkei to King William's Town which he carried them to Dimbaza to be handed over to Thembelani Xundu.  
	Chairperson, he told the Committee that he was given these weapons by Sipho Xuma.  Chairperson, this Committee knows about Sipho Xuma, that he was a Deputy Director of Operations in APLA, second in command to Letklapa Mpahlele and that he was also a Director of Special Operations and he was the man.  His name is always mentioned as it was also mentioned at Heidelberg Tavern and some also limitedly in St James, that he was the person who has been supplying arms, also in Johannesburg, that he's always involved when it comes to the supplying of weapons in all these operations.
	And as such he told the Committee everything and how the route he has taken and how everything was done, the car that was used up until they were handed over, until Major Xundu took them to Xnesha and put them in a DLB in Xnesha until the operation at the golf club.
	The fourth applicant, Lungisa Ntintili.  Chairperson, also the role he played was after the incident itself was to assist the applicant when they could not get back to Transkei and they required his assistance, that they have to dispose of the vehicle which they used in the operation because there were roadblocks all over and that police were after them.  So they had to take his car and drove in his car and they asked him to drive the car which they used in the operation, until they burnt it between Fort Beaufort and Grahamstown, on the road to Grahamstown.  
	So that was the role that was played, and also that he was asked to keep weapons which of course were used in a later incident at Yellowwoods.  He was asked to keep weapons.
	Chairperson, if one followed it, the whole incident and the whole evidence which has been adduced in the hearing, it's clear that the applicants that what they did was they acted on the instructions and they carried out the instructions.  They did not carry out the instructions for their own benefit, they carried them out on behalf and they believed that what they were doing was for the benefit of the struggle which they were waging.
	Chairperson, I would like to mention that also another applicant who was involved unfortunately passed away was Xhomiso Nonxuba who was the main man, Regional Commander who the applicants were reporting to.  Xhomiso Nonxuba was also involved in this operation and Mr Xundu was reporting to him directly as his immediate senior.  	And to remind the Committee that Xhomiso Nonxuba was also involved in the St James incident, he actively participated in St James with Thubela Mlambisa and others.
	One would also remember that also in Heidelberg, Xhomiso Nonxuba's name was mentioned as the person who instructed them to go to Cape Town, Gqomfa and others and he gave them money for transport and everything so that they will get weapons in Cape Town.  
	So if one looks at all these incidents, one would get a clear connection in all these incidents, that they emanate from one point which of course from the PAC, from APLA, because all of them they, it's an undisputed evidence in all these applications that they were indeed in the hierarchy of APLA and they were senior members of APLA and their Director of Operations was Letklapa Mpahlele, who they were eventually reporting to.
	Chairperson, having said that it is therefore my humble submission, without wasting the time of the Committee, that the applicants in this matter have met all the requirements of the Act in order for them to be granted amnesty.  And it is therefore my humble submission and my request that these four applicants should therefore be granted amnesty as they have complied with all the requirements of the Act.  Thank you Chairperson.  Unless the Committee - I will wait for the questions from the Committee if there are any.
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