MR SARDIWALLA
If one looks at the evidence, and I'll deal with that in a short while, I'm just making the broad submissions at this stage.   It is also my submission that client was not compelled to be here, he was not being sought after, he was leading a life otherwise relatively normal, but elected of his own accord to come in public to face the people that have been affected by the incident, the process of the law and make a full disclosure.  So I believe that within his memory and within the knowledge of what transpired, I submit he has in fact made a full disclosure.
	I'd like to now deal with these aspects relative to the evidence that was led.  If one looked at the evidence of the applicant and if one looks by and large at the factual sequence leading up to the incident that was decided on and that was adjudicated by the court in respect of the other two accused, except for the identities of the two people, the accused in that matter, the factual evidence more or less ties in to what was said by my client, the place that the incident took place, for example, the description of the road, the fact, and the Judge made some very strong statements regarding the conflict between the ANC and the IFP at the time and regards it as being common cause that there was this conflict at the time.  He found that, in his Judgment, that there was in fact common cause that there was a conflict during the time of this incident between the IFP and the ANC.
	What also appears to be clear from the evidence of my client, is that he was a member of the ANC.  That was undisputed.  There was some uncertainty about what organisation he belonged to prior to 1990, but I believe that is not as material to this application as his allegiance at the time of the incident.  I believe that evidence has not really been contested.