Your Worship, if I may refer the Court to the decision. of the Cape Provincial Division in Bell vs van Rensburq NO

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1 questioning of witnesses. Your Worship, if I may refer the Court to the decision of the Cape Provincial Division in Bell vs van Rensburq NO 1971 (3) 5ALR at p.693, a judgment of Mr Acting Justice Baker, your Worship will find that at page 707/8 of the report, reference is made to "die Verslag van die Kommissie van Ondersoek na Onluste in Durban". This was a Commission of Enquiry presided over by Appellate Judge van den Heever in Now this was obviously an important Commission. Now what happened there (10 was that some of the parties who attended this Enquiry wanted permission to cross-question witnesses, and his Lordship disallowed that opportunity, and in writing his report ultimately dealt with his reasons for doing so, and his Lordship said at page 708 sir: "In sommige gevalle het die advokate wat voor ons verskyn het en die sterkste aangedring het op die reg om getuies aan kruisverhoor te onderwerp uiters onbeholpe vertoon in die eenvoudige prosedure om n getuie te ondervra.. ( 2 0 Well I hope this is not of application to these proceedings sir. But his Lordship went on to say - "..0m sommige toe te laat om getuies onder kruisverhoor te neem sou willekeurige diskriminasie gewees het, maar as iedereen toegelaat moes word om elke ander getuie aan kruisverhoor te onderwerp, kon n mens net sowel n gepeupel onbedrewe swaardskermers in n donker kamer op mekaar losgelaat het. Daar sou groot lawaai, maar geen lig gewees het nie. Daar sou niks aan waarheid gewend kon word nie, en ons sittings (30 sou onmoontlik lank geduur het." Now/

2 Now I'm quoting this passage sir, why? Because I want to stress the fact that his Lordship, in coming to the decision to which I have referred sir, considered that it was necessary in the public interest that the sitting should not be unduly protracted, and that nothing should be permitted which would not contribute t o w a r d s. a a n die waarheid gewend kon word nie..". Now your Worship, in this case, a lot of evidence has already been led which we know is similar fact evidence, and some more evidence of that kind is being tendered at this ( stage. Your Worship we have already addressed you sir, at length, on the question of similar fact evidence, and we've also quoted the Metropolitan case to you sir, and we have also quoted to you from Hoffman's book on Evidence. Now I am merely alluding to this question at this stage, the question of similar fact evidence, because I would like to draw your attention once again to the fact that at page 21 of this text-book the authors say: "The disadvantage of receiving similar fact evidence is, in general, a waste of time which may be involved ( in examining collateral issues of the same kind as the main issue which the Court has to decide. " Now your Worship, I am talking of the same kind as the main issue which the Court has to decide. Your Worship I am talking about this question of the wastage of time. That it is necessary, for any presiding officer, in proceedings of the present nature, and in court cases and in Commissions of Enquiry, to be guarding against the fact that there is not an unnecessary waste of time, and a protraction which really serves no good purpose. ( Now your Worship, I think our learned friends in their argument/

3 argument have conceded that you have a discretion presently sir, in deciding what to do about these affidavits which have been tendered, and it was also said sir that you must exercise your discretion in a judicial manner; with that of course we agree. Now your Worship, we submit that you are enjoined sir, in exercising your discretion, to be mindful of the fact that you must contain these proceedings within reasonable limits, and ensure that the conduct of the Inquest does not pass out of your hands. This is something which is (10 stressed in the Timol case your Worship, and we would remind you sir, with great respect, of the fact that every witness in these proceedings is your witness sir, and not that of any party and we would submit sir that this is a critical stage, where your Worship's hold on this Inquest is being tested and being brought in jeopardy. Now your Worship it is necessary once again to turn to the events preceding your Worship's ruling of the 22nd of January, and in that connection sir, - 2nd of June - we would refer you to what appears at page 485 of the record. (20 Your Worship will recall that during the testimony of Sergeant Blom, the question of the admissibility of further statements came to the fore, and this is what fell from your Worship's lips at that stage: "Mr Bizos, sorry to interrupt, I think you have made a few valid points, but I think at this stage I want you to consider to hand in those statements as soon as possible." Our learned friend obviously has been referring to the fact that there would be certain further statements to be handed (30 to you sir. Now/

4 Now our learned friends then said they are ready to be handed in; "COURT - Affidavits? I want to read through the affidavits, and I want to consider the contents of the affidavits, I think that might place me in a much better position to decide on the admissibility of the questions, and whether the questions should be allowed or not. If the affidavits are not available at this state, I intend to let the witness stand down because that will assist me to make a Ruling on that type of cross-examination." Now your Worship, at page 487 your Worship said the following "..If necessary Mr Bizos, but I think I will be placed in a much better position if you give me all the information available to you, and then I'll be in the same position, I think it's much better." "We'll get it before you your Worship in proper form as soon as we possibly can", this is what my learned friend said, and we then also asked permission to say something sir, and we said the following : "Sir, save that I think we should also like to stress the fact that it has really become necessary for my learned friends now to produce the statements on which they have been working as far as we know, for a very long time, sir we wrote a letter to them which was also sent to you on the 1st of June this year, in connection with this aspect of the matter, and we also deem it extremely necessary, from the point of view that we will have to take instructions, we don't want to delay these proceedings." Our/

5 Our learned friends then went on at page at least, sorry sir, the Court then said ; "I hope so Mr Bizos, because I want to indicate to you if I consider it necessary to have all the statements available before I make any decision, any ruling in this matter, I will let this matter stand down until I've got all information the parties intend to hand in, all the information the parties intend to hand in. Nobody wants to delay the proceedings, but we must all try to co-operate and get it over as soon as pos- (10.sible." Now your Worship, at page 489 your Worship again referred to the question of further affidavits and said the following: "Mr Bizos, there is something I would like to mention. You did submit certain statements, but you also indi - cated that you intend to hand in more statements, more affidavits. I think it is rather difficult for me to decide on the matter, I haven't got all the statements. Is there a time limit within which you can submit all the statements you intend to submit for (20 consideration? That will place me in a much better position to control the examination of all the witnesses to be called in this matter". My learned friends then answer as follows: "..I want to assure you sir that every reasonable step is being taken to submit all the statements that we now know would be available. There are however sir certain practical difficulties..." and he then mentions the fact that there was to be contact with Mr de Vries, and that - who knows that at least one (30 case an arrangement is being made as soon as possible for him/

6 him to be present for the statement to be taken and soforth sir, but your Worship then at page 490 repeated yourself sir, in the following words: "I would also like to indicate that I do consider to postpone the matter to give you an opportunity to get all the statements to place me in a better position to judge on the admissibility of the examinattion." Lower down on the page your Worship said the following; "..There is one course I would not like to take, and that is to recall witnesses, if it can be avoided. (10 Now I am not saying that I am going to postpone the matter, but that is a possibility I am considering, because I want to be placed in a proper position, having all the information before me when I consider the course of examination to be allowed or not." Hr Bizos, my learned friend then says sir; "It is something that we understand after all, it was our submission your Worship will have noticed in our Heads of Argument, the question of admissibility will have to be decided on the part of all the information (20 before your Worship, but we are trying our best". Then we say sir: "May we also say something on this aspect your Worship? Your Worship, we do regard the present stage of these proceedings as somewhat of a cross-roads situation. As a result of the statements which have been handed in it might be necessary for us, depending on your decision sir, to explore various avenues, to consult with people, to take statements, and to deal with issues which we regard as side issues, and which we regard as really (30 irrelevant to these proceedings, but depending on your /

7 your decision sir, we might have to do that, and we haven't commenced anything in that direction simply because we are awaiting your decision in this regard sir, so also for that particular reason it is vital that there should be a stage where we have all the affidavits, and know where we are going." "COURT - Thankyou Mr Schabort, in the meantime as far as this witness is concerned, I have decided to allow Mr Bizos to cross-examine." (jq Now your Worship, at page 499 there was an issue ensueing from the fact that we made an objection concerning questions based on a statement, the admissibility of which had not yet been decided by.the Court, and flowing from that objection sir, at page 499 your Worship said the following: Your Worship then as a matter of fact, stood the witness down, in the following words: "I do not intend to give my ruling on this question whether this question is to be allowed or not now. The witness will stand down. My request is that all..." (20 and in the record the word "all" is underlined sir, obviously because of the stress placed on that word by your Worship,...My request is that all the affidavits to be obtained from other persons for consideration, be obtained and submitted to me as soon as possible because I am satisfied at this stage we have reached the stage that I will have to indicate whether I am going to allow the statements of other detainees or not. I think that will affect the course of the further examination of all the witnesses to come to the witness box, and I (30 do not intend to take this decision at this stage, because/

8 and/ cause I haven't got all the statements. I want to be placed in a proper position to place myself in a better position to make proper Rulings. I do appreciate that there are some difficulties to obtain these statements. I am afraid, although I appreciate the difficulty, I will have to direct the course of the proceedings, and I need the statements. If time is needed to obtain the statements I will adjourn the proceedings until Counsel for the family indicate to me that they are ready to submit the statements and (10 I will consider the statements immediately, and I will be giving a ruling on the admissibility of the statements immediately as soon as possible thereafter." Now your Worship, it is this part of the record, and these very important facts to which we must draw your attention sir, and to which our learned friends have not even alluded in the slightest manner. Your Worship, the statements were then filed and your Worship was called upon, I think it was on the 22nd of June, or whenever it w as, to consider and give a Ruling, and your (20 Worship has given a Ruling and that Ruling has been implemented sir to the letter. We have had all those codetainees whose evidence your Worship allowed, and - to come and give evidence sir, they have given evidence, and a number of police officers have also been called to give evidence in rebuttal, in refuting some of the things said. Now your Worship, we must submit to you that your Worship has set a deadline, for purposes of the lodging of affidavits, from co-detainees, as your Worship was perfectly entitled to do, as any judicial officer in your Worship's position (30 would have had the right to do, and your Worship has done so,

9 and this was not done without taking into consideration some difficulties that were being experienced by our learned friends, some difficulties which were overcome by them before they filed their last affidavit prior to the deadline set by your Worship, and your Worship we would submit that there is no reason and that no good reason has actually been advanced, why this Court should at this stage, set a new deadline, or extend the previous deadline to a new date. This Inquest sir has now taken up more than - well I think we saw in the newspapers about 34 days already, it (10 could be more than that, court days, over a period of approximately 6 months, and the completion thereof sir, even without the evidence of additional co-detainees will necessarily require a further substantial period of time. In fact sir, we would submit that this Inquest has reached the stage, where it has virtually become prohibitive of re-opening. Your Worship must consider the following, if the proposed co-detainee witnesses are called, at least nine police officers who have already testified, must be recalled, now your Worship I could give you their names, (20 but we have counted them, and if there is any dispute about this, then it would be very easy to find their names in the various affidavits and to draw your attention to them, but we submit sir that it will be necessary to recall at least nine police officers, who have already testified before you. At least 20 further police officers, who have been implicated will have to be called, in order sir, to traverse fully and thoroughly the disputes created by the acceptance of the fresh affidavits. The Inspector of detainees will have to be recalled, (30 and then sir, and we also have an interest in placing all evidence/

10 evidence before you that we could place before you sir, in order to try the issues created by the fresh affidavits, we submit sir that it would be necessary for us to consider whether to ask you to call additional police officers whose names do not feature in these affidavits. Doctors, magistrates, and poss-ibly even co-detainees as we might deem desirable to consult and call in order to traverse the accusations and allegations made. Now your Worship we know how much time has already been spent on considering the evidence of the co-detainees (10 so f ar. Our learned friend this morning questioned Mr Smith. Now your Worship, we submit with respect, if this particular issue of - if the issues concerning Mr Naidoo must be tried properly before you. Then your Worship we submit we have every right to ask you sir to also call Lieutenant Botes and call Warrant Officer Booysen, and call Lieutenant Steyn and several other people sir, it slipped my mind now. Well your Worship however that number would be multiplied many more times sir, should all these other persons now be per- (20 mitted to give evidence. Your Worship has now seen and heard, in examination and lengthy cross-examination by our learned friends, and by ourselves and by Counsel for the State the main characters in this matter. Officer de Bruyn, Persons like Lieutenant Whitehead, Warrant Sergeant van Schalkwyk, Warrant Officer Kerr, Warrant Officer Deetlefs, Dr Floyd and a number of codetainees. The Court has seen statements, notes produced by the deceased. The Court has also had a lot of evidence of the deceased's appearance during his detention, (30 including the period immediately before his death, and expert evidence/

11 evidence is still to be adduced, a lot of similar fact evidence your Worship, and hearsay evidence of the deceased's utterances have also been admitted. We submit with respect sir, that the issues before the Court have been properly investigated, and highlighted from all angles, and one may pose the queston whether the evidence of 8 more detainees, and scores of policemen and other witnesses, will really make any meaningful contribution to assist the Court in arriving at a decision. Your Worship (10 but that unfortunately, is not the last word. There is no guarantee that a fresh order, limiting the number of witnesses to be called, will not lead to a new spate of affidavits. Who says that our learned friends will not attempt to present some more affidavits at a later stage? On what basis will the Court then be able to refuse to call the witnesses, if witnesses are called at this stage? Your Worship, with due respect, this Inquest has, in our respectful submission, already assumed in some ways the (20 proportions of an enquiry into detention in general. A lot of evidence has for instance been canvassed on issues concerning the general conditions of detention and regulations relevant thereto. Furthermore sir, with regard to the evidence now before the Court, there is already room for a number of further witnesses to be called if the issues must be tried on the evidence of each and every one mentioned or implicated in that evidence, and I here allude to the example that I have given you sir, of Mr Naidoo's evidence. (30 Your Worship has already rejected the affidavits of Mr Ndao/

12 Ndao, Kgatshalia and Narsu. These witnesses failed at the propitious time, to supply the essential material in their affidavits upon which the Court could decide to call them. We submit that they have furnished inadequate reasons for not presenting the Court with all the available data at the time. Mr van Heerden was afforded a perfect opportunity, in detention, as a person detained, as a State witness, to furnish a statement to the Deputy Attorney- General, but he elected not to do so. Now, at this late stage sir, he suddenly pops up as a man who purports to be able to give material evidence on various aspects. We would submit that this bold farce of this nature at this stage, should not be suffered. He should not be permitted at this stage to divert this enquiry into directions which could have been explored in good time, had the allegations been made at the proper time. As regards Miss Hogan, here again your Worship there is some explanation for the fact that she has not given a statement before, but we submit sir, that both her explanation - well that her explanation is inadequate, and in any event sir, that this Court will simply have to retry issues already decided by a criminal court. There has been a prosecution sir, concerning the alleged assaults on her, that case has been tried. In the case of Mr Kwetha(?) this Court has already taken a decision, and we submit no good reasons have been advanced for a different decision at this stage. Your Worship, our learned friends opened their address to you this morning, by making some general observations - yes, well your Worship my attention has been drawn to the fact that we haven't seen the affidavits of Mr Denis van Heerden/

13 Heerden, Ruth Becker, and Dr Ivor Cohen, as well as - well then as far as Dr Jacobson is concerned, there is no affidavit apparently sir. Now your Worship as regards these general observations, the point was made that because we asked some of the police witnesses whether there was a system, that it seems to indicat that we are under the impression sir, that if they say there wasn't a system, then that's the end of the matter. Now sir, we agree that this Court will decide whether there was a system, and we don't say that the witnesses can decide that for this Court by their simple denials. A submission of that nature sir would be ludicrous. As regards the other point made, namely that there was one team who interrogated people and treated them unlawfully in various places, your Worship I - we sincerely believe sir that it is not necessary for us to address you again on this aspect of the case- We deny most strongly sir, that there was anything like one team who interrogated the deceased and these various other people. Your Worship, it is only necessary to remind you sir of the fact that Warrant Officer - at least, that Lieutenant Whitehead was only involved with Dr Aggett and Dr Floyd, and your Worship - or let me rather approach it from this angle; because of the fact that there was one police officer, in the person of Major Cronwright, who was the personnel head of all the investigators, it is sought to find the necessary link between the various, let's call them teams sir. Now we have already addressed you on this particular aspect sir and we have submitted that the fact that there is one commanding officer in a given situation, that that is not enough to find a basis for similar fact evidence. Your/

14 Your Worship, your Worship is mindful of the fact that there - and we have an affidavit which has been received from Brigadier Muller in which he sets out sir, details of the number of police officers involved in this big investigation, and the number of detainees and we know sir that of about 50 or actually 57 detainees at the relevant time, so far evidence or affidavits of only about 10 to 15 people have been produced. Now your Worship, there must be a system. It must be possible for you sir by logic to draw an inference that (10 the deceased was treated the way Hr Smithers says he was treated, because of similar fact evidence. Now we say sir that it is simply not possible to draw that logical conclusion, on the available data, and on the affidavits presently tendered to you. Now your Worship, in conclusion, it is quite true that there is Mr Ntonga whose affidavit apparently could not have been obtained before I think in early August, the codetainee who was in the Eastern Cape, detained there. Now your Worship, as regards that particular detainee and as (20 regards all the others, we submit sir that you are, with due respect, in charge of this Inquest, that you have set a date for purposes of your Ruling on the question of the admissibility of affidavits of this nature, and evidence, that you were obviously then alert to the fact that there were possibly many other co-detainees of the deceased who had not by then been approached by the lawyers for the family or who had not been in the position by then, to come forward and tender evidence. Your Worship, we have seen from newspaper reports, (30 and I think it is probably common knowledge, that in recent times/

15 times, I believe it's a Petition or something of that kind, has been presented to the Minister in which reference is made of accusations by very many co-detainees of alleged assaults on them. Now your Worship we say, that for purposes of this Inquest it was necessary for your Worship, it was practical and it was expedient, in the public interest and in the interests of those immediately involved, to draw a line somewhere, and your Worship has done that, with due notice to all of us, that that date and that day would have to come, when your Worship would want to be in possession of all the affidavits. Now that day came in June, and that day passed in June, and we submit sir, with great respect, that it is too late now for our learned friends, that it would lead to too many disturbances in these proceedings if there must be a virtual re-opening of this Inquest at this stage. It would not be warranted, it would be in conflict with your own Ruling sir, and we would accordingly urge upon you to disallow these affidavits. As regards Dr Jacobson sir, and the affidavits that we haven't seen, it's very difficult for us to say what they contain, as far as - well your Worship we would leave the position of Dr Jacobson in your hands. COURT I have received two statements coming from Dr Jacobson Mr Schabort, I don't know whether you have received any copy of any of these statements? ADV SCHABORT No sir, we haven't. COURT The one I received this morning, that was obtained on my request, and is with Mr de Vries, and I think he will give you a copy as soon as possible. ADV SCHABORT Yes sir. We might perhaps just indicate sir, that as far as Dr Jacobson is concerned, we haven't

16 Now/ seen his affidavit, and subject of course to what is actually contained in his affidavit, we won't dispute sir, that certain reports were made to him, such as those featuring in the documents which have already been placed before you sir, his certificates issued at the time, but other than that I don t think I can take that much further. COURT ADV BIZDS Thankyou Mr Schabort. I promise to finish sir, if your Worship gives me 5 or 7 minutes. COURT 5 Minutes Mr Bizos. I think that's too long, but (10 not more than 5. ADV BIZOS As your Worship pleases. Your Worship I am glad that my learned friend referred to the record because I think the answer to a certain extent to many of his objections are to be found in the record itself, I would refer your Worship to page 490 of the record, where your Worship is discussing the question of the statements, and you say: "What I would suggest with the greatest..." COURT You know I - I beg your pardon Mr Bizos - it is not necessary to read the record to me, I will read through the (20 record. ADV BIZOS Yes, no there is this sir that I want to draw attention, it's of the very nature of an enquiry sir, and may I just say sir for instance, someone as a result of a newspaper or other information, makes vital information to us, available to us tomorrow for the first time, I am sure your Worship will not reject it for that, and your Worship says that is something different, entirely different, "No, no of course sir, this is why - but I want to assure your Worship that we are trying our best to (30 continue as soon as possible..".

17 Now my learned friend sir, with the greatest respect, has told your Worship that we should have filed the affidavits then. The passages that he read to your Worship were recorded on the 14th of June. The - Ntonga was released on the 18th of August sir, van Heerden was released on the 6 th of July. Chikani was released on the 7th of July, Hogan has given an explanation, and I submit with respect sir that if one of the parties to the proceedings has witnesses in detention, it can hardly be held to blame for another party for not having filed affidavits timeously. (10 As far as Mr van Heerden is concerned sir, with the greatest respect to my learned friend, he could not have chosen a worse expression than that Mr Van Heerden had a perfect opportunity to make an affidavit. Your Worship knows, that even though this was a consultation with his legal representative sir, on the affidavits before your Worship, the information was handed over to Major Cronwright according to the latest affidavit placed before your Worship. With the greatest respect sir, that can hardly... COURT Do you want to come back at 2.00 o'clock Mr Bizos? (20 ADV BIZOS COURT ADV BIZOS Another two minutes if I may sir. Two minutes Mr Bizos. With the greatest respect sir, that is hardly the best opportunity. There has been no argument advanced to your Worship sir in relation to the non-similar fact evidence, the four witnesses that give direct evidence, and whatever your Worship's reservations may be, in relation to Kgatshalia, Ndao and the third person, there can be no doubt in relation to the others in my respectful submission. I submit further sir that the Bell and van Rensburq (30 case has no application, if it's any authority for the proposition/

18 sition is, sir that your Worship may receive the affidavits, and not allow cross-examination in my respectful submission sir, there can be no doubt, in view of the fact that the witnesses were kept in detention that your Worship will allow the - yes your Worship and it's - I am just reminded sir, that Mr van Heerden just didn't pop up, in my learned friend's words, he took the trouble of te l l i n g the Deputy Attorney- General whilst in detention, that he had vital information. Your Worship, for reasons which appear to have been wellfounded, he was not prepared to make an affidavit whilst in detention. COURT Mr Bizos, isn't it a possibility that you might explain to me why the attorney or Counsel who advised Mr van Heerden did not approach me or inform me? ADV BIZOS I don't know your Worship, I really don't know why he did not - why your Worship was not approached, but sir, with the greatest respect... COURT I was not informed, I was not informed why he refused to make the statement, not by the attorney or Counsel who advised him, according to his statement. ADV BIZOS Well your Worship, I don't know, I cannot answer for my colleagues, but it was made quite clear sir that access would not be given to us, so that what your Worship has to judge is have we been remiss in any way in getting the statement. If your Worship had sent the investigating officer, or anyone else I don't know what would have happened, but assume for a moment sir that your Worship should have been informed by his Counsel, that is no reason for excluding vital evidence as to what might have happened... COURT ADV BIZOS I think it is just a matter of courtesy Mr Bizos. Your Worship, I will convey, the personality

19 of the persons concerned are well known to me, they are my colleagues and I will convey your Worship's remark in that regard sir, I am sure that no discourtesy was intended. The police sir, claim absolute control over Mr van Heerden, and I would believe sir, in defence of my colleagues, that they probably thought that your Worship, as the courts have no power to interfere with a detainee, that your Worship had no power, and maybe that is why they may have been led into error, but I will most certainly convey your Worship's remark to my friends. COURT Thankyou Hr Bizos. Mnr de Vries, die verklarings wat ontvang is van Dr Jacobson en dan ook die wat mnr Bizos hulle ingehandig het, en Dr Cohen, sal u dit beskikbaar stel aan die partye asseblief, sodat almal weet waaroor dit gaan. ADV DE VRIES Dit sal gedoen word. HOF Baie dankie - we have already discussed the matter of going on with this matter after today, I am not available on Thursday and Friday, Mr Bizos is not available 3 days next week, and we have decided to postpone t his matter until the 25th of October, 1982 in the same courtroom. AT THIS STAGE MATTER REMANDED TO 25th OCTOBER 1982

20 Historical Papers, Wits University Collection Number: AK2216 AGGETT, Dr Neil, Inquest, 1982 PUBLISHER: Publisher:- Historical Papers Research Archive Location:- Johannesburg 2013 LEGAL NOTICES: Copyright Notice: All materials on the Historical Papers website are protected by South African copyright law and may not be reproduced, distributed, transmitted, displayed, or otherwise published in any format, without the prior written permission of the copyright owner. Disclaimer and Terms of Use: Provided that you maintain all copyright and other notices contained therein, you may download material (one machine readable copy and one print copy per page) for your personal and/or educational non-commercial use only. People using these records relating to the archives of Historical Papers, The Library, University of the Witwatersrand, Johannesburg, are reminded that such records sometimes contain material which is uncorroborated, inaccurate, distorted or untrue. While these digital records are true facsimiles of paper documents and the information contained herein is obtained from sources believed to be accurate and reliable, Historical Papers, University of the Witwatersrand has not independently verified their content. Consequently, the University is not responsible for any errors or omissions and excludes any and all liability for any errors in or omissions from the information on the website or any related information on third party websites accessible from this website. This document is part of a collection deposited at the Historical Papers Research Archive at The University of the Witwatersrand. 07:52:17 AM]