MR MADASA - IN FURTHER ARGUMENT
Yes, thank you, Mr
Chair, yes the applicants, inasmuch as they do not know how Vips was killed, but they persist on the application because they felt they were involved because their act of capturing him was associated with the killing of Vips.   That is my short answer, Mr Chair.
	Mr Chair, just one point on Tusanang, which my learned friend seems to be wanting the committee to accept his credibility.   I'm thinking of, for example, he said the Youth League only had two AK47's, it was the arms they had, but now it transpires, for example, Thabo, with whom he went to Blanko's place, had a revolver, and from other evidence which is in (indistinct), they had other sort of firearms.  All right.
	Mr Chair, an important point I want to raise on the issue of section 20 again, my learned friend has, as it was pointed out by Mr Chair, that he was intending to state that his submission was that the target of the SDU, that is the ANC Youth League, was not a State or a political opponent.   My answer to that is that section 23, which is an expansion of the meaning of political objective, the criteria given there, especially I want to draw Mr Chair's attention to 3(d), 3(d) specifically, amongst other things, that when this question is looked at, the objective or objective of the act or mission ordered, but not only the State but State property, personnel, or against private property or individuals.   So individuals are now included, and I submit that the ANC Youth League, from the perspective of the SDU, for example, could be seen as those individuals.  But besides that, even if you, it can be viewed, rather they can be viewed as part of the State machinery if they were seen as being infiltrated, which is what the applicants have been saying right through their application.
	Mr Chair, especially the evidence of Michael Nkomo, Moishe August Ndabe, Armoed, all these people, in their evidence in chief, when I dealt with the political objective, they all mentioned the fact that in addition to Blanko's case, they perceived these people as agents of the State.
	On the issue of, Mr Chair, of the community, that these people were not taken to the community and the community did not order their killings, I submit, with respect, Mr Chair, that as it is apparent from the evidence, as much as we are not told how the SDU execute people, it's clear, Mr Chair, that the community would never order executions.   I mean people had their own relatives within the (indistinct), how could they, there would have been discord, therefore it's obvious that it was a matter of SDU separately to decide whether, what should be done to people, but the community had to know.   So I submit that the issue of taking these people to the shack before the community was for the community to see the people who were involved.   Hence it is said Dondolo called the SDU members aside, because that was a matter now for SDU's to decide on the issues of killings.  The community would never have ordered killings, I submit, Mr Chair.