MR BANADE
Mr Chairman, I would like to make use of the opportunity granted to me and start by referring to section 21 of the relevant Act.
	As you are well aware, there are mainly two important provisions and that is that this Committee, after considering the application, has to be satisfied that the relevant Act - and here we are referring to the murder of Jama - had to have been done with a political motive.  And interestingly enough, there are also references made to the conflict of the past.  
	The second aspect is the applications of all the relevant facts being put before the Committee, full disclosure that is, and the further requirements are these contained in section 22 and in submission all three applicants resort to ... (CHANGE-OVER TO TAPE 2B)
2B - 11.2	... As/...
MR BANADE	113	ADDRESS
... As far as full facts go ... that is probably the aspect that bothers the Committee, otherwise I do not understand the detail which has been gone into. 
	In submission, the facts in question were brought before Judge Thirion in court beyond a reasonable doubt, and that is why all three of them were convicted of murder.  So there can be absolutely no doubt that they are murderers.  
	The finer details as to why they stopped, why the person was searched, who saw what, with all due respect had to and in anyone's memory would have somewhat become vague by now.  The applicants have absolutely no reason to come here and lie before this Committee and I think that can be accepted.  What they said before, and specifically before the Court, should be differentiated from what they have said today, if there are some differences, because the aim in a criminal trial is adversary.  Facts are withheld and others are emphasised.  But, it is the State's duty to prove the case beyond a reasonable doubt, whereas here the facts are being brought to the fore as far as they can remember and to disclose, as far as they can remember, fully to the Committee.  
	In submission, Sir, if there are differences in their versions, it is with regard to smaller aspects.  The fact is, and that has been proven beyond a reasonable doubt, and they acknowledge, that a certain ANC supporter had been murdered by them.  So as far as the Act refers to - I would say that it should be read in connection with the full disclosure.  The Act refers to "full" disclosure, and it should once again be read in the light of the fact that this incident took place six years ago, and everyone's memory is not as good.  And this is one aspect I would like to touch
2B - 11.2	upon/...
MR BANADE	114	ADDRESS
upon, the fact that there were verbal agreements in certain paragraphs in the submission of Harrington and Erasmus.  
	You have to take into cognizance that they are being held together and I would like to bring to your attention, after I had consulted with them and given the main facts they were told right, you go and do this on your own, and that was on a Saturday afternoon where I instructed them to fill in the missing pieces, and that they might have consulted with each other.  Under those circumstances,  that is neither here nor there.  
	Harrington is the one who was consulted with more verbally and in his submission Mr Erasmus borrowed some of his terminology.  I do not think that it should affect their credibility before you in any way.