MR BRINK
Well, with respect, absolutely, it is a wholly improbable claim that men running out into the open, running down a road, perhaps entering the veld, could be cornered in any sense.  It is wholly improbable.  Therein lies, that expose, that give the lie to the claim made in the application form that the men were cornered and then shot from different directions.
	I don't think I have highlighted this, I have mentioned the cutting of the telephone wires and the handset to the wireless radio, but the point is this.
	If the police trusted the assurances of the applicants, as has been alleged, that they were not to come to any harm, then the severing of the telephone wires and the radio wireless microphone, handset, is unexplained.
	It looks, I mean that evidence coupled with the buttons, the cartridge, who knows what happened there, but coupled with the buttons, suggest struggle, suggest struggle.
	We are in the dark to when Sergeant Mbhele's teeth were broken, but it seems likely that there was a struggle at the police station, he was assaulted there.  It also seems most improbable, most improbable on its face, that four armed men arriving at a police station, out numbering two police Sergeants who - they were evidently taken by surprise, it seems improbable that these four armed men arriving hostile, weapons drawn, would be able to persuade two policemen who they insisted on abducting, that they are not going to come to any harm, just come peacefully and they complied.  It seems most unlikely.  Again the buttons suggest otherwise.
	To claim the benefit, namely immunity which was created by the machinery of this act, it is a fundamental essential unavoidable requirement that the applicants make a full and frank disclosure of all the relevant facts, of all the material facts.
	In conclusion, it is my submission that they haven't done so and that they haven't done so is manifestly obvious.
	It is a matter of overwhelming probability and on account of the discrepancies between the evidence given viva voce today, the evidence given on paper in the affidavit and the unsworn claims appearing in the application forms.
	Those are my submissions.  I move for the dismissal of all four applications.