So, your Honours, the emotional mental effect of what was done to this witness and what he observed or learnt about what happened to him is relevant for us in many respects. (1) is the fact in circumstances surrounding the crime committed and (2) goes to Count 1 of our indictment which is acts of terrorism. As you know, elements of acts of terrorism are acts or threat of violence directed against protected person, or their property, and one of the elements is the offender willfully made protected person or their property the object of those acts or threats of violence.
Now, the act or threats of violence were committed with the primary purpose of spreading terror among the protected persons. Now while it is not required to prove that the actions in fact terrorised the person, the effect on the person of the act is relevant to establishing that the act was committed with the primary purpose of spreading terror.
Now it goes as well to Count 7, which is violence to life, cruel treatment, and violence to life one of the elements is causing serious harm to mental or physical health.
It goes to Count 8, which is other inhuman acts, and again one of the elements is that the perpetrator inflicted great suffering, or serious injury to body, or physical, or mental health by means of an inhuman act.
Finally it goes to Count 10, enslavement, and as you know one of the elements is that the perpetrator exercised any or all of the power attaching to the right of ownership of a person such as by purchasing, selling, lending, or bartering such person, or by imposing on them a similar deprivation of liberty. Now, the effect of the actions taken against the witness and those he observed, or learned, or if any other manners, are relevant to those deprivation of liberty and exercise of ownership.
So, for all these reasons it is our case that it is that we are entitled to ask this question and I do not think that the extent of what he may say was covered by his testimony yesterday. That is our submission.