MR WILKINSON
Thank you Chairperson.  Initially I would like to submit that the third applicant and his application as currently before the Committee, complies with all the requirements laid down by the Act.  It's also my submission that the applicant, in his evidence before the Committee disclosed all the relevant facts, made full disclosure of those facts.  And it's my submission that all the applicants for that reason disclosed these facts with - in such a way that the interpretation of those facts today, should be such that there was no remorse.  It is my respectful submission that it was the cold-hearted truth and in the presentation of that truth, there wasn't remorse as such.
	In Section 22(b) the Act stipulates certain criteria, six criteria to explain what is meant by an act committed with a political objective.  Eight of these criteria independently and in the light of the circumstances of the case must be considered.  
	As far as possible we should distinguish these criteria but there will be a large measure of overlapping and that's unavoidable.  And we therefore request that the criteria in sub-section three must be seen as a whole.
	It is my respectful submission that a too strict application of these criteria would result in a fact that the objectives of this Act would not be realised and cannot be realised if we act too strictly.  There will be a measure of overlapping and flexibility must be applied.  It's clear from the documents relating to the trial and the documents presented before the Commission, that during the attack, there was no question of any personal benefit or gain.  It cannot be argued that the deaths happened out of sense of fear of later identification.  The organisations were important role-players at the time.  The PAC launched an attack against innocent people that morning and there was a counter-reaction later that day by the Orde Boerevolk.
	As far as motive is concerned, it seems from the evidence of the applicant that the motive was politically inspired.  He said that he was a member of the Orde Boerevolk and he therefore signed a declaration of war.  During his detention, under Section 29 of the Internal Security Act, there was also a charge of high treason investigated against him.  It's probably as a result of the magnitude and the seriousness of the crimes of which he was later convicted.  This particular case against him was not proceeded with.  The crime was not investigated by a normal investigating team but by a special riot unit which also shows that the State's perception of the Act at that particular stage, was definitely that it was a political crime rather than a normal common crime.
	He was detained for 96 days without trial, as already mentioned.  And the trial court, Judge Hugo specifically said, that the offence was committed for political motive.  The context in which the act was committed was in reaction to the PAC's attack that morning.  There was a general shock amongst the right-wing community of Richard's Bay as a result of this attack and it's clear from the evidence that in the course of the day, that was the only point of discussion in Richard's Bay in that shop, the applicant's shop.  The attack that night on a passenger bus was therefore a clear reaction to the attack of that morning.  
	During the trial Judge Hugo also said the following during sentence"
"What happened was clearly a catalyst for the evening's attack as far as the legal and factual nature of the crimes is concerned".
It is so that the Act constituted a grave human rights violation ...[intervention]