UNKNOWN
Thank you, Chairperson.
	The argument here is at two levels.  The first relates to, well we say is an important matter of general principle and that is the circumstances under which it might ever be proportional to target civilian politicians for murder. 
	The second level relates then to proportionality in relation to the particular individual.  In other words, if you are against us and even if you were to find that sufficient is here being led to justify the proportionality of targeting civilian, certain classes of civilian politicians for assassination, then we would say well, then let's look at the proportionality in relation to particular individuals and shortly there must then be a difference between a Gavin Evans and a Dullah Omar and a bunch of kids who go to a meeting in a hall in Athlone.
	Now we start of in paragraph 61 saying that we refer to the well known Constitutional Court decision in Makwanane about proportionality and we submit that inherent in the notion of proportionality is whether the desired ends could reasonably be achieved through other means less damaging.  This is of considerable significance in the context.  That test is of considerable significance in the context of this case because you will recall that the applicants were cross-examined at some length on this issue and we say that there's no reason why that test should not equally apply to the concept of proportionality.  Within the context of the TRC Act it's difficult to perceive of any other real meaning that can be attached to proportionality.
	Moving then to page 33, paragraph 62.  We say that the test must be premised on the understanding that the CCB was there to act on behalf of the State to maximally disrupt the enemy.  Now you will recall, starting off with the cross-examination of Joe Verster, that we got involved in this issue and what was put up really by the applicants was an argument which tended to suggest that this Committee must assess the CCB on the premise that they are some sort of hermetically sealed unit separate and apart from the State and that you can't really ask them what other machinery was available to the State as a whole to take steps against people like Omar or Evans.