MR CURRIN
We would ask to alter the form accordingly.  There is also one other alteration which I wish to draw to
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your attention.  Reference is made to Judge Waddington, that should be Judge Friedman.  We apologise for that error.
	The second requirement is, we need to satisfy you that the offence is associated with a political objective, and that we will deal with shortly.  
	Thirdly, that the offence was committed in the course of the conflicts of the past.  
	Now in dealing with the previous one, namely, that the offence is associated with the political objective, we will simultaneously refer very briefly to conflicts of the past.  There has been an indication that that is accepted.  So we will certainly not belabour on that point.
	Then finally, we need to satisfy the Committee that the applicants have made a full disclosure of all relevant facts.  We believe that the applicants have made a full disclosure and unless we are questioned on that, we will assume that that particular leg or requirement has been met.
	We will now have reference to the requirement that the offence is associated with a political objective.  With reference to section 20 of the Act there are two aspects which we would like to refer to.  
	First of all, an act associated with a political objective is defined as meaning an offence, constitutes an offence or delict which according to the criteria in subsection (3) is associated with a political objective and which was advised, planned, directed, commanded, ordered or committed within or outside the Republic of South Africa during the period of 1 March 1960 to the cut-off date, which we know is December 1993, by any member or supporter of a publicly known political organisation or liberation movement, on behalf of or in support of such organisation or
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movement, bona fide, in furtherance of a political struggle waged by such organisation or movement against the State or any former State or another publicly known political organisation.
	Now before referring to the criteria, I would just like to make a very short submission, and that is that we believe that we have proved through the evidence of the two applicants, that they were members of a publicly known organisation, namely the African National Congress, and that furthermore there is evidence that they associated with the aims and objectives of the African National Congress.