MR WILLIAMS
Yes, thank you Chairperson.  Mr Chairperson, we've heard the evidence of Mr Andile as well as the evidence of the applicant.  It is my respectful submission that there's nothing inherently improbable in the evidence of Mr Andile Jack.  His evidence is logical, it's coherent and it's consistent.
	My learned colleague Mr Riley said that he gained the impression that Mr Andile Jack drew inferences when he testified about the fact that he heard the perpetrators calling out the name of Mr Pro Jack, but Mr Chairperson, Mr Riley does not tell us on which facts does he gain that impression.  On the contrary I get the impression that Mr Andile did not draw inferences because his direct testimony is consistently that he himself heard people calling out the name and he also says that Mr Pro Jack also said that people were calling him.
	Mr Chairperson, the evidence on record is also that there was no-one else in the immediate vicinity and an argument which runs that other people might have called him, is based purely on conjecture and does not tally with the facts before this Commission.  It is also my respectful submission that that also does not tally with the probabilities, it does not tie in with the probabilities that the testimony of Andile is that they were driving in the car, they heard someone calling out Pro Jack's name, they then reversed and the fact of the reversal of the motor vehicle is important here, Mr Chairperson because it then explains or, let me put it this way, it explains the fact that they heard someone calling out his name and it is therefore more probable that someone did call out his name and that is the reason why he reversed.
	Mr Chairperson, with respect, if one looks at the testimony of the applicant, his version is riddled with contradictions, inconsistencies and improbabilities and I just want to refer the Commission to a few of those.  
	As far as contradictions are concerned, it might be minor aspects, but if one looks at his testimony as a whole, it diminishes the value of his testimony.  He says at some stage that when his statement was taken, that he was not explained his right to legal representation, he later contradicts this evidence.  He also initially says that he was pressurised into making a statement, he later contradicts this statement and says that it was voluntarily made.  When asked whether high-placed ANC officials knew about his actions, he says yes, but then he goes on and he directly denies that they knew it.  He says that when Chris Hani approached him, he denied any knowledge and when Msondile Jacobs approached him, he denied knowledge.  
	If I look at some of the inconsistencies of his testimony, the following few emerge.  Firstly, he says that they went out looking for a police van and it is common cause that the vehicle in question, a Golf, does not resemble a police vehicle in any way.  When asked why he did not go to the ANC and tell them, he says that he was waiting for someone to ask him, but yet he also testified that numerous people asked him, Msondile Jacobs asked him, Chris Hani asked him, other people also asked him but he denied it.  He says further that Mr Mthama was his Commander, but then he also goes on and then the effect of his testimony is that Mthama wasn't really his Commander.  He also says that Mthama knew that they were going out to attack the police and when he asked why didn't he tell the people beforehand that they were going to attack the police, he said no he was scared that the police might arrive there and wait for him.  These also are inconsistencies which I wish to point out.  
	Mr Chairperson, I also want to show quite a few improbabilities in his version.  The applicant states that he did not hear the vehicle or see the lights until the vehicle was two to three metres away from him.  Now with respect, Mr Chairperson, I want to submit that this is highly, extremely improbable, given the fact that the applicant was a trained cadre, he went out on a mission, he had experience in those type of missions.  He knew that he had to be cautious, he had to be alert and he would in all probability have noticed the vehicle beyond two or three metres from him.  So I want to say that his testimony in that regard is highly improbable.
	Mr Chairperson, it is also highly improbable that Mr Pro Jack  would leave his path of travel and then for some inexplicable reason, go to the place where the applicant and his friends were hiding.  Go, for some inexplicable reason, leave his path of travel and go to the trees.  That doesn't make sense to me, it doesn't tie in with the probabilities and Andile's evidence in this regard makes more sense.   Mr Chairperson ...(intervention)