MR WILLS
Thank you, Mr Chairperson.
	I submit that my client, Mr Gold, also satisfies the requirements as contained in Section 20 (i) of the Act in that first of all his application complies with the requirements of the Act, that the Act was an act committed with a political objective, committed in the course of the conflicts of the past and that the applicant has made a full disclosure.  He too falls under Section (ii) (b) in that he was an employee of the State, acting within the course and duties or within the scope of his express authority and the act was directed against a known liberation movement at the time.  As regards the aspect of whether or not the act was bona fide, I think that's clear and it's amply described in his viva voce evidence, but succinctly in paragraph 20 (i) of his affidavit on page 12 where he indicates how he was totally convinced that his role in operating against the ANC and its communist influence, was the right thing for any loyal South African to do.
	I don't think, with respect, that there can be any question about whether or not he should have followed the instruction given to him by his superior, the then Lieutenant van Zyl, particularly in the light of the fact that at a later stage there was even a more senior officer present, which would have, from his perspective, as he indicated, corroborated the fact that that decision came from a higher authority and particularly in view of the fact that my client had a relatively junior rank, in the circumstances.  
	In any event, I submit that should the Committee find that he doesn't meet that criteria, which I submit it  should, with respect, he therefore would still fall into the category of Section 20 (ii) (f) where he was acting on reasonable grounds.  I submit that is quite clear.
	His political motivation, it was quite clear, is based on an order and that hasn't been disputed.  As regards the full disclosure, he has made a detailed affidavit and indicated to the best of his knowledge, taking into account this incident occurred 20 years ago, he's relayed every material fact.  I think what is significant in this application is the Committee can see that whilst the parties have been represented by different counsel, that they largely corroborate each other and clearly that I think supports the fact that they are all ...(intervention)