ADV PRIOR
Yes, and that is my submission.   Maybe the Committee does not have to maybe go there, which would be my alternative argument, that I don't - my submission is that we are not incorrect, we are not acting unlawfully if we produce as Evidence Leaders, part of the Amnesty Committee, the Section 29 proceedings as envisaged by the Section.   I would submit in any event, there is a far wider interest which is catered for by the Act in respect of the first proposition that having regard to those principles of openness and transparency, this Committee ought to allow it in any event.
	Finally, we are indebted to both legal representatives of the victims and of the applicant, the fifth applicant, both their Heads of Argument are very helpful, however, if I may just briefly refer to paragraph 1 of Mr Dehal's Heads.  With submission, all three points that he makes, being the basis of the objection to the inclusion, I submit are without any real substance.  Subparagraph (a), I submit flies in the face of the clear language of Section 29(5), his argument that Section 29 evidence was never intended to be included in these or any other proceedings, is without any legal or factual foundation.  Paragraph (b), he submits that by agreement at the 29 enquiry on the 21st of April 1996, the evidence is protected.  With respect, there is nothing from the preamble or the prelude to those proceedings.  If one gleans from the record, there was never any agreement struck between the Commission and the fifth applicant to that effect, and with submission, even if that was so, such agreement in the language or in the intention of the Section, would not have been proper, it would have been void.  It would not have been a binding agreement, because the Act does not allow for such an agreement to be struck.   
	And thirdly, subparagraph (c), I submit has been adequately canvassed by Mr Richard on behalf of the victims that privilege does not exist in the sense in which it was argued, and certainly I would also go along with Judge Pillay's reference to privilege if in the broader sense, it has a particular meaning in so far as such evidence would not be allowed to be used in proceedings where there was a penal sanction or the possibility of a penal sanction.  I would submit it would only be appropriate in that limited instance.  Those are my submissions, thank you Mr Chairman.