MR DU TOIT
I think that the argument of course is not that there should be any coercive moment in the consideration, but if the broader interests of the Act can be served, and it is striking in fact, Mr Commissioner, that the Act in fact says that it is necessary for the wellbeing of South African citizens - that is the broader community - and peace that there should be reconciliation and reconstruction.  That can only take place if what happened in the past is known so that we can move into the future, as Pastor Ray McCauley said so graphically.  We
	/can't move
can't move into the future if we don't know what happened in the past.  What would you be doing is not to say, "Well, there's a sword hanging over the head of the Committee.  If I don't give it then people may not come forward," because rightly or wrongly that may be the effect, and of course it is not the only consideration.  But if you want really to serve the aims of this Act I would submit that that is indeed an important consideration.
I would submit that you have before you a factual basis.  It tells a story.  It tells the story of an abnormal situation.  It tells the story of policing in a society which was everything but normal at that point in time.  I would submit that if you apply the criteria to the factual basis before you the decision which is justified on the facts would be that the criteria are satisfied.  In my view there is no suggestion, and there cannot be any suggestion, that the criteria as set out in section 20 (3) are not satisfied.  The facts are there.
I would ask my colleague to conclude our argument for the application.