MR TRENGOVE
The applicant will in the first place seek amnesty for everything that he did in the three capacities he mentioned.  Firstly as instructor.  Secondly as member of the command of special operations and thirdly as chief of ordinance.  The application in other words in the first place relates to his own conduct and not to the conduct of other people.  That conduct of his in those three capacities, everything that he did in those three capacities rendered him liable, both civilly and criminally for the conduct of others within the country, whether on the basis that he was a co-perpetrator in certain of the consequential offences committed within the country and the delicts committed in the country, or on the basis that he was an accomplice or an instigator of those who committee the offences and delicts within the country.
	So that his application for amnesty relates in the first place to all his conduct from mid-1978 to 1994 in the three capacities we have identified.  That conduct would have rendered him liable civilly and criminally at least for the crimes and delicts committed by those directly under his command, but we would submit on the basis of the doctrine of common purpose also for those who were not directly under his command but acted on behalf of MK within the country. 
	Insofar as those offences and delicts are capable of identification they have been identified in his evidence with reference to the general MK list in the first place, and with reference to his own special operations list in the second place.  
	But those crimes and delicts for which he will also specifically seek amnesty are crimes and delicts for which he is liable on the secondary basis as we've explained by reason of his conduct in the three capacities that we have referred to.  
	There may well have been, as he has explained, many other crimes and delicts not included in those lists for the reasons that he has given to the Commission. 
	And therefore, and so far as he accepts that he may be criminally and civilly liable for crimes and delicts within the country committed by others, he is unable to furnish the Commission with a complete list.  And it is to that extent that he seeks amnesty for crimes and delicts which he is unable to identify. But what he is able to do is to describe his own acts and omissions which render him so liable, i.e. his own conduct in his capacity as instructor, leadership of special operations and chief of ordinance.  
	Now it speaks for itself that the witness doesn't remember everything that he did on every day from mid-1978 to 1994.  So in that sense I suppose it would be correct to say that he doesn't have a recollection today of every act and every omission for which he seeks amnesty, but he certainly has a general recollection of everything he did during that period, and has testified to it and has offered to give further particulars of it insofar as it might be required.