MR DU TOIT
Thank you, Mr Chairperson.  I intend briefly introducing the evidence which I seek to lead in support of the application, but I must first thank my learned colleague, Mr Kajee, for placing on record that there is no opposition.  I must also extend my thanks on behalf of the applicant that the community is willing to receive him in their midst, because he has informed me that it is his intention to visit the community at an arranged date to offer his personal apologies.  And we are grateful therefore that the application is not opposed by those who 	/have been,
have been, as my colleague indicated, so tragically affected by what happened.
The application will show that my client joined the South African Police Force when he was 18 years of age in December of 1975.  Certain personal matters will be covered briefly by verbal evidence, since it is before you and your fellow Commissioners in the lengthy affidavit which was placed before you.  
The evidence will show that my client was not involved in what one would call normal policing at all.  In fact he spent only a short period of his rather lengthy career doing normal policing, and I can tell you that in respect of that I have received letters from members of the community, unsolicited, expressing gratitude for what he did.  The evidence will show that my client, almost immediately after he completed his training, was involved in riot control.  When he was not involved in the control of riots and political strife, political problems, he was in the then South West Africa, where he fought SWAPO.  I must also say that it is an outstanding feature of his service that so little time was spent on what one would normally describe as policing in a normal society.
So it happened then that in roughly February of 1987 he became involved in what is called - or what is known as the Joint Management System.  He was made a staff officer and attached to the Divisional Headquarters in Pietermaritzburg.  There he became the secretary of the Regional Joint Management Committee, and evidence will be led to explain what this was and what its main function was.  In his capacity as secretary of the system he came in possession of certain documents, inter alia a strategy 
	/document
document compiled by a general of the South African Police headquarters in Pretoria, setting out the police involvement and implementation in what was called the total strategy against what was seen as the total onslaught.
Mr Chairperson, Commissioners, the evidence will show, and the document itself will show, that there was devised a Government management philosophy, or a strategy, which covered most aspects of life.  It covered, for example, the church domain, education, media, the so-called alternative media, and in fact dealt, as I have said, with almost every terrain or domain of life itself.
More particularly of relevant to my client, however, is the strategy which is set out in this particular document to the effect that people will be taken from the black communities, trained as so-called special constables, or "kits konstabels," and will then be taken back into the communities to win back physically land areas lost to the UDF/ANC or the Comrades, as they are called.  The strategy is to claim back inch by inch land or areas already lost, and to prevent further gains on the side of the UDF/ANC combination active at that point in time.
The documents which have been placed before you already by my client will show that at first a small number of special constables were employed and trained, and, because of what is described as the success they experienced in winning back inch by inch certain of the areas now dominated by the UDF, at some stage in '87 and also in the beginning of 1988 roughly 16 000 special constables were added to the police force consisting of 
/48 000.
48 000.  This force was considered to be an auxiliary force, and it was born out of the then Rhodesia.  The force of special constables were deployed throughout the country as a result of the strategy set out in this particular document, annexure A to the affidavit of my client, the applicant.  In this process of deployment the special constables were taken all over the country and attached mainly to Riot Units.  The Riot Units used the special constables in order to regain area, land lost to the UDF, and/or to prevent further claims made successfully by the UDF.
A research document of the Catholic Institute for International Relations, which we have attached to the application, and to which I will refer my client so that he can confirm the contents thereof as also how he saw it, shows that on the 1st of March of 1988 300 special constables were deployed in the Pietermaritzburg area.  The then Minister of Law and Order announced that the special constables will be deployed in Pietermaritzburg to restore law and order within the Pietermaritzburg divisional area, and probably also the KwaZulu-Natal or Natal area.  Despite church protestations, protestations from the church, the constables were deployed and the Defence Force elements or Defence Force members were removed from the area.  The document is of a view that this was done in order to deploy the special constables successfully.
My client, in his capacity as secretary of a Joint Management Centre, divisionally seen within the headquarters of Pietermaritzburg Police, also came into possession of certain documentation which was handed to 
	/students
students at a police training centre called Milierskop(?).  The lectures were available at the headquarters to Riot Unit members, more senior people, in the form of a manual.  The manual, and one of the lectures more particularly, deals with the clandestine operations of the South African Police secretly operating in small black townships.  It is, of course, needless to say that this is highly relevant to the application which was placed before you.  	The evidence will therefore show that there was an approach within the South African Police Force that not an inch will be lost, and that inches lost will be regained, and when my client took up position as station commander of the New Hanover police district he in fact became the ex officio chairperson of the local or mini Joint Management Centre, and it was his duty, as it was the duty of station commanders all over the country, to implement this strategy which I have summarised briefly.
The judgment of His Lordship, Mr Justice Wilson, showed that the motive behind his conduct in Trust Feed in fact was to interfere with the political dispensation, to interfere with political gains made by a UDF aligned organisation, and it is quite clear that my client, on the instructions of a superior officer, Captain Terblanche, the local officer commanding of the Riot Unit, called Riot Unit 8, caused specials to be delivered to the Trust Feed area, where, in line with the manual, they arrived in an unmarked kombi and in civilian clothing after dark.  And, as the judgment clearly shows, the special constables were used in an attack that evening.  
The Riot Unit operated in some instances, as it did 
here, as a sweeping instrument.  In other words it would 
	/move into
move into an area, mostly UDF dominated, and it would then sweep the area of the young Comrades of weapons in order to prepare the area for an attack, which would then take place later during the evening.  This attack would be launched by Inkatha or Inkatha Youth Brigade, as it also happened here, and there would be support from special constables.
The special constables were used, as the strategy document also sets out, as a physical wedge against what was called the tyranny of the Comrades, the idea being that the policing will acquire a black face, as is also clearly demonstrated in this research document which we traced, and that it would be possible for the black policemen to act offensively within certain smaller areas on a clandestine basis.   
The evidence will show, therefore, that my client's conduct was a politically motivated, that it was as a result of what he knew, and the instructions were orders of a Major - Captain, later Major Terblanche.  It is necessary to state that the evidence will show that Major Terblanche was, some time after the event, killed by a special constable.  The special constable in his turn was killed by members of the Murder and Robbery Squad.  My client's information, which he will briefly refer to, is that that was done in order to prevent the relevant special constable, that is the person who killed Major Terblanche, to reveal that other such attacks in which the special constables were used took place in the Hammarsdale area and various other areas within the Natal territory.
Mr Chairperson ... (intervention)