MS PATEL
Thank you Honourable Chairperson.
Honourable Chairperson, it is my respectful submission that none of the applicants have met the requirements of the Act, that they were not politically motivated when they embarked on any of these operations, that none of them have made full disclosure.  It is my further submission that none of the grounds that the applicants have tendered here have differed from that tendered at the trial court and I accordingly request, humbly request that you accept the decision made by the Judge at the trial where it was found that none of the - despite the fact that it was accepted, the political scenario was accepted, the decision taken at the meetings in December was accepted, it was found that none of the accused or the applicants at that time were motivated by any high minded political idealism.  I would ask you all to also take into consideration that the applicants had all applied for indemnity that one of the criteria that they had to meet at that indemnity application was in fact that their crimes were politically motivated.  They in fact failed in their indemnity application, I would submit that that is of highly persuasive value to yourselves when you come to a decision as to whether they were in fact politically motivated or not.  In as much as there might have been a decision taken by the community, we have heard clearly from Mr Bhayi what the ambit of that decision was and without going into the specifics of all the applicants, it is my respectful submission that none of them abided by the specifics of the decision and the manner in which these operations were meant to carry out.
	As an example one looks at Mr Hansel, if one looks at the motivation for the decision that was taken by the community, it was conceded by the applicant, Jimmy Nokawusana, that Mr Hansel was in fact a good person and would never have fallen within the ambit of that decision.  
	One looks further at the housebreaking of Mr Senti, the fact that he was shot, the entire scenario fell clearly outside the ambit of that decision.  It is my respectful submission, Honourable Chairperson, that when one looks at political motivation, even if, and this not conceded, even if it is accepted that the applicants were carrying out the decision of the community, if one looks at the question of proportionality which you are required to do in terms of Section 20, sub-section 3 of the Act, we look at all the victims, they were all old, they were all alone.  To a large extent they were not in a position to protect themselves save for Mr Cobus who managed to stave off the attackers for quite some time.