MR WILLS
Thank you Ms Committee Member.  My submission in this regard would be that had that been the case, the applicant was fully armed with a whole arsenal of weapons, which one can see at the final stages of my argument, and he could have quite easily taken that person out completely, without referring the matter to anybody else.  Instead he took the matter to his commander, Mr Mkhize, he disclosed the problem to Mr Mkhize, but even more than that the matter was raised with Gideon Zulu and others at a meeting at Ulundi.  Now there would have been no necessity for that, in my submission, had there, had he just wanted to kill Gumede for the purpose of trying to cover things up.  What I think is the probably is in fact what Mr Mbambo suggests, is that he honestly felt that his was a ploy of the ANC to get him off the streets in Izingolweni, and I think if one considers the evidence in totality, particularly the issue of how the KwaZulu policemen in Izingolweni were investigating the crimes of their colleagues, covering up evidence, and the fact that the ANC had no recourse to the police station, one can understand that these types of desperate measures or different tactics to get rid of a person, would ensue.  For example, there's no motor vehicle theft unit in Izingolweni with the KwaZulu police.  One would have to go to the South African police to get that sort of thing investigated.  That's the first thing.
	And secondly the ANC had lost all faith in reporting incidents to that police station, because there was no success in investigating the issues.  And that in itself would make it far easier for Mbambo to have killed Gumede.  Because he could have killed Gumede and the matter simply wouldn't have been investigated, like the hundreds of other issues that weren't investigated.
	I submit as well in the totality of the evidence, I mean you're touching on the issue of personal gain, there is not one iota of evidence where any of the applicants whom I represent got anything for anything that they did, other than the salaries that they got as policemen.
Now, the only, turning to the incidents of what I've loosely referred to as the indiscriminate attacks, and I use the word indiscriminate specifically in the context that the victims were not identifiably, but the attacks were discriminate in the sense that they were directed against either ANC persons or ANC areas.  But referring to that was what I considered to be quite a seminal event in the history of Izingolweni, and that was the incident where the IFP had a rally in February 1992 at the Izingolweni station, stadium, and Prince Gideon Zulu was due to address that rally, and it was disrupted by the ANC to the extent that Prince Gideon Zulu couldn't deliver his speech as he intended.  And from that point on, right in the presence of Mbabmo and later at a meeting called at Izingolweni specifically to discuss that problem, Gideon Zulu issued the instructions to the effect that "...we must do to the ANC what they are doing to us."  And by that he was referring specifically to these attacks on ANC busses and the like in areas without specifically targeting people.  And that was seminal in the sense that it was only after that that the applicants who I represent, should I say the applicants who'd only been operating in Izingolweni, got involved in that sort of violence.