GEORGE BIZOS
There are additional documents filed by the objectors, which have not yet been paginated.  We will take care of it in due course in consultation with counsel for the Commission so that all those facts which really is an attempt to define the issues before you, we will put them all into that file.
	Now, Mr Chairman, our approach to this matter is that this is neither an appeal nor a review of the judgment given by his Lordship, Mr Justice Nugent.  The Committee has a statutory duty to perform which, or the section in it which deals with what it has to enquire into and make up its mind and give a decision on the facts and circumstances that have been placed before it.  Nothing said by Nugent, J is binding on this Committee.  	We do not have to quote authority for this proposition, because the learned Judge himself on an early page of his judgment clearly states that inquest findings are not bound on anyone, they are made on a prima facie basis and that in any event there is a different test and different legal requirements in this regard.  	Now, we have attempted by asking a number of questions before to place before you facts by way of admission and for that purpose we served a document on the objectors, which is the document before you, pages 1 to 12 in which various questions were asked.  We thought that we would obtain sufficient information about what we believe to be matters which were either common cause or not seriously contested by way of admission.  It is with some regret that we wish to place on record that the objectors did not avail themselves of this opportunity of responding to what we believe were facts which ought to be either common cause or not seriously disputed.  
	The other was that right at the outset on page 2, Mr Chairman, we asked questions in order to identify the objectors and tell us what it is, what harm they have suffered in order that the Committee may decide as to whether their injuries, if any, and precisely where they were injured and whether their injuries really qualify them as objectors proper.  I'm not of course speaking in relation to the eight deceased, Mr Chairman.  Unfortunately we have not had much joy as a response, but more importantly on page 3 we asked the following questions:
"The objectors are requested to state on what grounds each of them intends to oppose the applications for amnesty;"
Paragraph 3 -
"If it is alleged that the applications do not comply with the requirements of the promotion of national unity and reconciliation, Act no 34 of 1995, the objectors are requested to identify the applications which allegedly do not comply with the requirements of the Act;"
 and 3.2 -
"To specify in what respects the said applications allegedly do not comply with the requirements of the Act.  If it is alleged that the acts of offences to which the applications relate are not acts associated with a political objective committed in the course of the conflicts of the past in accordance with the provisions of Section 22, 23 of the Act, the objectors are requested.  To identify the acts or offences which allegedly are not acts associated with a political objective, committed in the course of the conflicts of the past and in accordance with the provisions of Sections 22 and 23 of the Act;"
and 4.2 -   
"To specify in what respect the said acts or offences allegedly are not acts associated with a political objective, committed in the course of the conflicts of the past and in accordance with the provisions of Sections 20.2 and 20.3 of the Act;"
5
"If it is alleged that the applicants for amnesty have not made a full disclosure of all relevant facts, each of the objectors is requested to identify the applicants for amnesty who allegedly have not made a full disclosure of all relevant facts, and in respect of each applicant for amnesty to specify in what respect the said applicants for amnesty has allegedly not made a full disclosure of all the relevant facts and to specify all relevant facts which the said applicants for amnesty has allegedly failed to disclose."
	Now, we want to indicate to you Mr Chairman, the answers.  Unfortunately not all the documents have not all been paginated but the first one has, it is the applicant's request for further particulars and admissions on page 108.
	This was a response by Mosselson & Associates in a document dated the 5th of May and Miss van der Westhuizen has associated herself with the answers given, so this is the document of those two objectors, and in relation to paragraph 2 they say on page 111 -
"The applicants are referred to the affidavits by the objectors in this regard."
The affidavits by the objectors in relation to this issue is to be found on page - I'm sorry, we have paginated it for ourselves, and we will try and persuade counsel for the Committee to paginate the same.  It's at page 122 -
"I have been advised that the applications of the guards who were injured do not comply with the requirements of the promotion of the National Unity and Reconciliation Act, and state that full legal argument of this point will be advanced before the Commission at the hearing of the matter."