GEORGE BIZOS
Yes.  	Now, then, Mr Chairman, page 4
"Purpose of the demonstrations, protests, march - Anti-election campaign"
If you could go back to page 3: 
"Names of all the organisers - Humphrey Ndlovu"
on page 3 and it will emerge during the course of the evidence that Mr Humphrey Ndlovu is not an Induna or a representative of His Majesty the King of the Zulus, but a member of the IFP and a senior office bearer of what was then known as Transvaal, and particularly the western branch, and that it was in that capacity that he put these matters into motion.
	Then, page 4:
"Purpose of the demonstration protest - Anti-election campaign"
not the King's demands, Mr Chairman.  Now, the fact that marches and not only a gathering was envisaged by Mr Ndlovu is proved by the answer to the question:
"Route which procession would follow or venue for staging demonstration"
on page 4, towards the bottom, Mr Chairman, 
"people will come from different destinations and some will be coming around the town and suburbs of Johannesburg."
So, we submit that this is a clear indication that it was anticipated that there would be marches, and that they would be coming on trains and foot, on page 5:
"And for what purpose"
again:
"the anti-election campaign".
	If you would turn, Mr Chairman, to pages 15 and 16 of bundle B, you will observe an indemnity given and entered into by the Inkatha Freedom Party and not His Majesty the King, or anyone else, represented by one Peter B Mangwasa, who says:
"On behalf of and duly authorised to by the Organisation"
and the organisation is defined in the first whereas on page 15 as the Inkatha Freedom Party.  They indemnify and hold ...(inaudible) the counsel and others Mr Chairman.  It's signed on the 25th of March and it's duly witnessed.  
	Now, there can be no doubt in our mind as to who organised this and we submit that the evidence clearly, placed before you clearly shows that.  We also ask that Mr Humphrey Ndlovu and Mr Themba Nkosa, in their capacities as senior office bearers of the IFP were instrumental in the conception of the gathering at the Library Gardens and the associated marches.  The response is the same, the one says "I can't admit or deny" and the other denies.  	Now, we will place material before the Committee by reading transcripts of telephone conversations on the morning of the 28th of March 1994, again which became available to all our learned friends at or about the beginning of the inquest in April 1997 and our learned friends have had copies of these.  They have listened to evidence in relation to the provenance and authenticity of these transcripts and they should have had no difficulty in making an admission in that regard, but - if you could please turn page 101 of bundle B and refer you to the hand-written portion:
"H Ndlovu and Captain Wilken"
Both these persons gave evidence at the inquest.  Our learned friends could ascertain quite easily whether they should make an admission or not but the contents clearly show that Captain Wilken, who was identified as the Liaison Officer of the South African Police and the conversation was at 07h45 in the morning.  They are apparently on good terms, because the first entry is: 
"Humphrey!, good morning and how are you."
		"Hi I'm looking for you.  I wanted to page you but I'm on my way to the office."    
		"Humphrey, listen, we have big problems this morning, man."
		"Where?"
		"You know, in Alexander, at the Hostels.  People are throwing stones to the vehicles.  They are shooting, shooting at the policemen who have got big chaos in town.  I wonder, can you make contact with the people at the Hostels, man, to tell them to discipline and come into town?  Either discipline, or we're going to have big problems today."
		"I see."  
		"You know really, we want to give our full support, but the people seems to me, they're getting out of hand now, man.  We need your support, but from your side Humphrey as well, you must try your utmost to calm the people down and tell them they must not loot the places or throw stones, etc."
		"That is true."
		"Otherwise we're gonna have chaos in town this morning.  Tell me, Humphrey, another thing, are you going to the election office as well?"
We will ask you to not the election offices, because there was an attempt to occupy the Electoral Commission offices and we will prove that Mr Chairman, as evidence of what these peace loving people were doing on the streets of Johannesburg on that day.
"No, I want to, I hear the statements that they are going."
		"I heard it over the radio, you see, that's why I want to ask you from you personally, are you people going there today."
		"No, they are not marching."
		"You are not going there."
		"No, we are just going to our spot where we stay there until disperse."
		"At the Library Gardens?"
		"At the Library Gardens, that is all."
		"And you will also be addressing the people there, and I am asking you to please before we put everything there, to bring the dogs."
		"What time are you going to put things together, Humphrey?"
		"We are going to start now."
		"Okay, I want to do that for the dogs too."
		"Okay, I will arrange that.  That is no problem, I will arrange that."
		"And I will also help you on this side for the people to behave."
		"I will be there, but Humphrey, I want you as the leader, to announce to the people there on the ground when you are addressing the people, to behave and to discipline, etc.  Please, man."
		"Really, I will do it, Sir.  Okay, I will do it, Sir."
		"Okay, please I would like your co-operation there, Humphrey, man."
		"Okay."
		"But I will see you on the ground then."
		"Alright then."
		"Okay, Humphrey, bye."
Now, remember, Mr Chairman, what the question was that the gathering at the Library - I beg your pardon, 3, that Mr Humphrey Ndlovu and Mr Themba Nkosa, in their capacities as senior office bearers of the IFP, were instrumental in the conception of the gathering at the Library Gardens and the associated marches.  The one denies it, the other one says they don't know.  They can so easily have found out and can so easily make an admission, Mr Chairman.  
	Let us now deal with Mr Themba Nkosa because the question was concerned with him as well.  Could you please turn to page 98 on bundle B, Mr Chairman.  I'm sorry, can you just bear one moment, one of our - we'll just find the page, my page is different to Mr Tipp's.   On page ...(indistinct) 28th of March '94, this too was produced by the Attorney-General's office and handed to the parties at the commencement of the inquest proceedings and if we look at it, we submit that in the absence of an admission the Committee ought not to have much difficulty in finding as a fact that together with Mr Ndlovu, Mr Nkosa was orchestrating the happenings on the streets of Johannesburg on the day in question.  
"Themba your people ne, are breaking down the place, man."
We will refer to this later for another purpose, but let us -
"Your people",
says Mr Wilkins, the Senior Police Officer who obviously knows Mr Themba Nkosa quite well, and what is his answer,
"you must expect that"
You must expect that my people will break the place down.  Mr Chairman, we are becoming impatient with the attitude of the persons that are opposing these proceedings and who were at the inquest.  We asked them a simple question which can be answered truthfully on behalf of their clients, when they have the information.  We ...[indistinct] foot to the proof of it, and we are told that this was a peaceful march for a demand of their things.  
"No, man, there's people on their way to work now, and they're throwing stones, etc, etc, and I don't want to act, man, is their now way that we can make contact with the people at the hostels and tell them to just don't throw stones and that stuff?
		MR NKOSA:   "I have a problem"
		"Yes?"
		"Things have changed now, you know, I don't need to tell you.  It looked like Inkatha is not going to be the same all the way now, so it's a question of expect that."
		"What area are you referring to?"
		"I am referring George Kok, all the hostels, man, and the road from Alexandra.  Since this morning, man, they've been throwing stones."
		"Yes, people are coming to work now."
		"That's our main problem, otherwise, you know, I've been in touch with the Stability Unit, they want to block the people not from coming into town."
The next sentence has great significance we will submit as to what happened that day, and what Mr Themba Nkosa's authority was,
"Tell them not to try that"
Mr Themba Nkosa, a senior IFP official tells a senior policeman who appeals to him to use his good offices to stop intimidation and other crimes being committed, otherwise they may have to stop the people from coming into town, his response tantamounts to a threat:
"Tell them not to try that"
What we're saying is that that is proof absolute by way of admission by Mr Nkosa that he was orchestrating the events, that he was, if not orchestrating, most certainly involved.  It was an IFP march ...[intervention]