ADV PRIOR
Mr Chairman, I don't think we should confuse the issues here.  We all understand that APLA was operating as a military organisation and they had specific targets and objectives for a specific purpose.  And even for example, if one looks at the attacks on motorists at the Mayaphuti Bridge, and even if one accepts that white people going about their normal business were legitimate targets, the question of gravity and proportionality must feature in the final analysis because APLA, as we've heard in the submissions, weren't an undisciplined organisation, they had structures, they regarded themselves as soldiers.  In terms of their own 15 points of conduct they weren't able to mistreat captives or prisoners and their own rules made provision for that.
	Now Mr Schroeder who had been injured seriously, shot through the body, lying there, to have his head blown away as it was, or Mr Tsemane who was assisting Mrs Brummer who had been shot or injured, I submit it goes beyond what a soldier does, it goes beyond the objective.  They had achieved their objective, it wasn't necessary, it wasn't justified, it served no political purpose or objective to execute the people as they did.  And that is the question that Mr Lax has properly put, therein lies the proportionality, that the deaths weren't justified in those specific circumstances.
	And understanding everything that has been said and understanding about the way they operated on the ground, we have understanding to that, but once they had finished the attack it seems that the people were in a very callous and cold-blooded manner dispatched, when it was totally unnecessary to do so.  So I submit that that is a factor or a feature that this Committee must bear in mind and must strongly weigh against the simple statement that we were carrying out orders and we had no ...  Mr Dolo was the regional commander, he wasn't a foot-soldier as has been correctly pointed out, he could decide.  They went on training runs, as the Committee heard, they tested their weapons, they were able to withdraw, they were able to choose, they weren't simply robots carrying out orders under pain of death.  Thank you, Mr Chairman.