ADV TEE
Mr Chair, if I may just complete the argument, because it is important if I read to you, I agree exactly with what you have said here, because he said at the top of page 36, he directed the statement to Mr Joe Nkuna. He said,
"Mr Nkuna, we want you to bear in mind that our clients, that is the ANC and the victims are not opposing your application for amnesty, but opposing the incomplete disclosure by you in support of your application".
and that is where I wish to address my argument.  Now, in reply to me, Mr Chair, you have just said that one of the reasons why he is going to oppose it is because Joe Nkuna did not say that he was present at the actual attack.  Now, I do not recall Mr Patel ever having cross-examined to that point.  What seemed to be the tack and the trend of the question relating to disclosure varied all the time, but what we do not have out of the mouth of Mr Patel is where does he allege the disclosure was not full, on what actual points.  There has been no evidence led by the victims despite frequent requests and so on as to what could have been disclosed that was not disclosed.  There has been no aspect of this case in respect of which we can say Joe Nkuna's evidence can be gainsaid by something else that has been led to contradict that.  
	What we do know is that some cross-examination concerning the initial attack on Joe Nkuna himself related to an affair, but that was not taken up.  Some cross-examination related to the conflicts within the ANC relating to funds, but ...