traditional council areas, page-19

Kiwi the application would not be treated as a community application unless it was 104 -Bengs application was not - it was one for rights to a BEE entity - first come first served. And it is not a matter of using another form. A 104 is directly submitted to the minister and not regional DMR.

The community 104 was an afterthought. I would have thought that the community were ignorant. But as stated the major engineer forming Bengwenyama Mins was a lawyer.......I dont see why he would not have known of 104. My hypothesis is that they believed that they were first in till very late. ...that is why 'the chief expressed surprise'.