MR NEL
Yes thank you, Chairperson.
	As I've indicated at previous hearings, I'm always in the position, the nice position to argue after senior counsel so there is not much more that I can say but with regards to my applicants, Chairperson, I can only submit that it's my humble submission that my clients submitted their application for amnesty on the prescribed form.  It's my submission to this Committee that the Acts to which these applications are related are associated with a political objective committed in the course of the conflict of the past.  The main focus lies on Section 20, sub-section 1 (a), (b) and (c) and I do submit that those requirements have been met.  
	Of course the other hurdle that my clients have is to place them in the category as mentioned in Section 20, 2(a) to (g) and I respectfully submit, Chairperson, that all three of my clients falls within sub-sections (b) and (f) that being employment of the State and they believe that they were acting in the course and scope of their duties.
	Finally, Chairperson, the provisions of Section 20 3(i) and (ii) excludes a person if he acted for personal gain or out of personal malice or ill will or spite and I do, with respect, submit that my clients did not do that.