MR SHEZI
Thank you, Mr Chairman.  Mr Chairman, first with regard to the application by Nofomela, it is apparent and even from his evidence, both under cross
examination and his evidence in chief, even though the point was not canvassed in much detail by his legal representative that there was no political motive.  In fact under cross-examination it would appear that Nofomela, he himself never had any political motive, nor was he even aware or sure of the political motive of his masters, that there was any.   All that one can submit, Mr Chairman, is that he just followed orders and on those basis Mr Chairman, his application ought to fail.
	However, Mr Chairman, the significance of his application serves to highlight one point, that the Chesterville Incident, with regard to that incident and how it came about, there were more forces at play and that there was planning, there was conspiracy.  Infiltration, as one understands it, whether in the manner it was being used or applied or practised at the time, or if one follows the convention or the dictionary meaning of the word infiltration, it is not something that can be done within the span of a short space of time and something which can just be delegated to some junior officers or to some junior members of the operation.  It is something which is normally well-planned, with such precision.  For Mr Radebe to come and say their instructions were to go, infiltrate, look for information about Charles, if you find any, well and good, if you find no co-operation, kidnap them, come back with them.  That Mr Chairman I submit doesn't make sense. 
	 Mr Radebe in his statement which he made subsequent to the event, he says they came after he had decided that the people in the room must be arrested on whatever basis, however questionable that basis might be.  They took up positions around the shack.  What for, it is not clear and even the whole question of arrest, it was canvassed thoroughly during Mr Radebe's cross-examination and some questions came from the Chairman and the Panel, that how did they go about arresting you know, when they asked other members of the group to go out?  
	My submission in that regard, Mr Chairman, is that this was part of a plan, they took position because they intended to shoot and calling out the other members was that it's now time.  The whole plan of going to Chesterville was to, I submit, assemble as much comrades as you can, wherever you can and then shoot.  This was very much well-planned, use and AK to elicit their co-operation and their trust and then once they trust you, then you can shoot them.  And it is not something that Sgt Radebe and the askaris that were in his company, with respect, Mr Radebe's competence and capability, it is something that I submit it was not within his domain to plan and do, but somebody in the higher echelons of the C10 Vlakplaas Unit had to do.  
	Mr Eugene de Kock was the Commander of the C10 Vlakplaas Unit which came down from Durban to Pretoria, yet according to Mr Vermeulen, when this aspect was discussed of going to Chesterville or of rather conducting the search of the killers of Security Policemen at the initial briefing the Commander was not there.  This whole thing of going to Chesterville, it would appear that it was just an initiative by Willie Nortje.  The taking of the AK47 which was under the control of Commander de Kock and who had requested it, somewhere at some point in time he never knew where it was, he never knew it was controlled, Willie Nortje could take it and go wherever he wanted to go.  I submit even some junior member of the Unit could have taken it to Umlazi or to kwaMashu if Sgt Vermeulen was to be believed.  
	Also and finally Mr Chairman, Mr Vermeulen applies for amnesty for unlawful possession of a firearm, an AK47.  His evidence under cross-examination reveals that both in fact and in law, he never possessed any firearm.  Under cross-examination he told this Hearing that in fact he did not even know that there was even a firearm in the vehicle he was driving from Pretoria to Durban and he only saw it, or alternatively became aware of it when Willie Nortje handed it over to Sgt Radebe, somewhere in Chesterville.