MR WILLS
Yes, thank you Mr Chairperson. ...(inaudible)
	Members of the Committee I act for four of what must be described as foot soldiers of the IFP's military machine, and persons who were primarily responsible for the actual killings on the ground.  Like Mr Stewart I have annexed to my Heads a list as Annexure A of all the matters, all the incidents, which the applicant whom I represent, in respect of which they apply for amnesty.  Obviously I think that it's clear to the Committee, its' very difficult to be specific about the offences, simply because of the lack of evidence as regards who the victims were and also because of the large time scale involved.  It's very difficult to give actual dates and link that up to any event at any particular place, but be that as it may I still think it's important that we maintain our application for amnesty in respect of these matter, even 'though the details are somewhat vague, particularly in the light of developments that it appears that in respect of people who haven't applied there is going to be an attempt by the Department of Justice to prosecute those persons.  And I think in the circumstances it would be extremely unfair to these applicants, who I submit are some of the few that have taken the Commission and the Committee, I say the Commission and the Committee, both the Human Rights Violations Committee and the Amnesty Committee, in to their confidence to such an extent.  
	I think rather than just following my Heads I'd like to just deal with the issue which is last in my Heads, and that is the issue of full disclosure.  I know it's not really a big issue in this case.  I just want to make the point that even 'though the person whom I represent are in gaol for certain offences, they represent a small proportion, or a small amount, of the acts in which they were involved.  And in fact in the majority of incidents no-one would have known about the fact that these incidents had taken place, had it not been for the applicants themselves coming forward.  So clearly one cannot ascribe the fact that they're in prison to their application to, or their application for amnesty.  In fact the converse is true.  I'm not sure if it's part of the evidence, I think it did come out in one of the applicant's evidence, that they made the revelations to the Goldstone Commission well before this Act was published, and they've been helping the State with investigations since late 1993 or early 94.
	I've divided the argument up into geographical areas, but first of all I think it's important to look at the context, and this is the overall context, which in my submission, applies to all the incidents in all the areas at all times.  The first, and I think most important thing, is the simple fact that all of the members were part of a military operation which Inkatha had set up with the express purpose of, I think in Luthuli's words, eliminating the ANC in KwaZulu Natal.  	Now it is my submission that every act that was committed by the applicants who I represent, was associated with that objective.  It's clear that, from Luthuli's evidence, that Inkatha had decided to form an armed wing to fight the ANC.  My case is slightly different to that of Mr Stewart's, because from the fact that the applicants who I represent are in fact foot soldiers, it's my submission that they had the general instruction to carry out these attacks from people in higher authority, and it's clear from Mr Luthuli's evidence, and specifically my cross-examination of Mr Luthuli, that he knew more or less what each of these applicants were doing.  Possibly not with each specific incident, but clearly their main purpose of, as I say, eliminating the UDF was well known to him and he supported them.