UNKNOWN
Very briefly Mr Chairman, as far as the application relating to Ntuli is concerned and that is the one where in his sworn statement he indicated that that took place before the elections of 1994.  He made it quite clear that this murder was committed after he had been released from prison in July 1994 which clearly puts it beyond the cut-off date. While it is perfectly true that the man's memory was to some extent unreliable, likewise his sworn affidavit was unreliable so you can't place any value on what he said in that statement relating to when Ntuli's murder took place.
	The second point I wish to make is that he clearly was, as Mr Chairman has pointed out, not acting on behalf of the IFP as a political party or indeed on behalf of the KwaZulu government at that time.   It appears that he comes close to the personal gain matter which is referred to in Section 20 subsection (1). (a) I: Personal gain.  His evidence was that he would not have committed any of these offences had he not been made an offer of employment and of gainful employment that is.  
	My submission Mr Chairman, that can well be interpreted as having done these things for personal gain, promise of a job in the then KwaZulu Police. Those are my submissions.