'Marikana miners shot while surrendering'
The commission of inquiry has heard some miners were killed while surrendering.
The commission has been hearing arguments for more than 18 months to establish, among other things, why police used live ammunition on striking Lonmin miners in August 2012.
President Jacob Zuma set up the commission to determine whether police were justified in using lethal force on the day 34 miners were gunned down during a confrontation with police in the North West mining town.
Lawyer for the miners' families, Dumisa Ntsebeza, showed the commission pictures on a projector of the body of a miner covered in blood.
The post-mortem showed a bullet entered the miner's back and exited the front of his body.
Ntsebeza said this indicated that this miner was clearly not charging at police or threatening their lives.
"This is not a person who would have been shot while charging the person who was shooting him."
Other miners were wounded in their hands.
Ntsebeza argued this showed some of the men were killed while raising their arms, which is a sign of surrender.
Proceedings will resume on Thursday morning.
The commission is being chaired by retired Judge Ian Farlam.