MS PATEL
Thank you Honourable Chairperson.  I will start in chronological order as the events took place.  However, before I start on the merits of, or my submissions in respect of the different events for which amnesty
is being sought, I would however comment on the applicants' position that they have likened their position in society in a sense to that of the liberation movements.  In a sense the flip-side of that submission, Honourable Chairperson, is that neither of the applicants were subject to forced removals under the previous government.  They were not subjected to the inferior education system.  They were beneficiaries of the apartheid system in respect of the separate development policies.  There were questions - not the questions, there was the policy of job reservations and better employment opportunities and most importantly, the were not disenfranchised under the previous regime, Honourable Chairperson.  Accordingly, they had the right to mobilise and wield whatever political clout they could muster to achieve their objectives, that in fact a limited democracy reigned supreme in the country during the time in which these offences were committed.
	Be that as it may Honourable Chairperson, I would like to move on to the question of the application in respect of Mr van Jaarsveld.  It is my respectful submission in response to Mr Terre'blanche's submission, that he relies on certain ex post facto facts or information that has come to light in terms of the submission made by the late Mr van Jaarsveld's son, in relying on their political motivation at the time.
	It is my respectful submission Honourable Chairperson that the applicant is not entitled to rely on evidence and information that came to light after the incident had in fact taken place in order to support his political motivation at the time.
	My second point in respect of that incident, Honourable Chairperson, is the question of whether one is motivated by a difference and a religious dispute, whether that amounts to a political motivation in terms of our enabling legislation.  It is my respectful submission Honourable Chairperson, that it in fact does not.  The applicant has said time and time again that his attack on Mr van Jaarsveld was in fact motivated by Mr van Jaarsveld trying to change history and more importantly was to tear them, was Mr van Jaarsveld's motivation to tear them away from God which comprised the bigger part of their culture.  If that is indeed the motivation, Honourable Chairperson, where does one then draw the line?  Can one then not argue that everything in life where one, that everything in life is in fact political that it affects your culture to a greater or lesser degree.  To use an example, let's assume that under the previous government an applicant stands before us having committed an offence against someone of a different sexual orientation and his argument is that heterosexuality is a part of his culture and that is what he wanted to preserve and that is indeed then his political motivation in that he wants to support a particular way of life.  Can we then say that this is the brief of this Commission?