BERNARD MAKGABO NGOEPE
Can I then take my point to it's ultimate conclusion.  I'm leaving aside the question of the list because there are arguments both and for.  Now you have said that if we take the bulk of, shall I say the poison or sting out of allegations against her, it will leave her with mere knowledge that, oh, these people were busy planning to do this and she should have known about, let's assume she knew about it, didn't go the police and the like, if we do find that she did know, then obviously it would mean that the Applicants did not tell the truth about it to the extent that they wanted to tell us that Mrs Derby-Lewis knew nothing, they would have lied to us.
	Now, would such a non-disclosure be a material one.  The failure to disclose knowledge on the part of somebody who did no more than just merely knew about it.